Ms. Alyson Schroer
Scarbrough International
7280 NW 87th Terrace Kansas City, MO 64153

RE: The tariff classification of vacuum insulated panels from China.

Dear Ms. Schroer:

In your letter dated March 29, 2023, you requested a tariff classification ruling on behalf of your client, MaxQ Research LLC.

The merchandise under consideration is vacuum insulated panels, referred to as “VIPs,” that are designed to keep blood cool during transport. Samples were submitted with your ruling request and were retained by this office.

You state that the VIPs come in four sizes: 436 millimeters long by 210 millimeters wide by 5 millimeters thick; 518 millimeters long by 150 millimeters wide by 5 millimeters thick; 482 millimeters long by 230 millimeters wide by 10 millimeters thick; and 530 millimeters long by 140 millimeters wide by 10 millimeters thick.  They consist of a core layer wrapped in a thin layer of non-woven fabric and covered with a barrier film. From the information you provided, the core layer is comprised of 82 percent by weight of fumed silica, 15 percent by weight of opacifiers, and 3 percent by weight of glass fibers.

The applicable subheading for the vacuum insulated panels will be 6815.99.4170, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Articles of stone or of other mineral substances…not elsewhere specified or included:  Other articles:  Other:  Other:  Other.” The general rate of duty will be Free.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 6815.99.4170, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty.  At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 6815.99.4170, HTSUS, listed above.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at

This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Nicole Sullivan at [email protected].


Steven A. Mack
National Commodity Specialist Division