CLA-2-85:RR:E:NC:N1:113 R05114

Ms. Shelly Watschun
Bradley Corporation
W142 N9101 Fountain Blvd.
Menomonee Falls, WI 53051

RE: The tariff classification of a combination towel dispenser, hand dryer and waste receptacle

Dear Ms. Watschun:

In your letter dated October 25 2006, you requested a tariff classification ruling.

The merchandise is a combination towel dispenser, hand dryer, and waste receptacle housed together in a stainless steel cabinet (item number 270). This recessed unit will be installed in public restrooms. The cabinet measures approximately 56 inches in height and 15 inches in width. It is also available in a semi-recessed model (item number 270-10) and surface-mounted model (item number 270-11). The paper towel dispenser is made of stainless steel and is located at the top of the cabinet. Below the towel dispenser is a sensor operated, electronic hand dryer. A plastic waste container with a 16.5-liter capacity rests in the bottom of the cabinet

The applicable subheading for the multi-purpose unit will be 8516.33.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for electric instantaneous or storage water heaters and immersion heaters; electric space heating apparatus and soil heating apparatus; electrothermic hair dressing apparatus…and hand dryers. The rate of duty will be free.

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 on World Wide Web at

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist James Smyth at 646-733-3018.


Robert B. Swierupski
National Commodity
Specialist Division