CLA-2-73:OT:RR:NC:N1:121
Ms. Antonella Proietto
Schenker of Canada Limited
On behalf of Mobile Climate Control, Inc.
7540 Jane Street
Vaughan, ON L4K 0A6 Canada
RE: The tariff classification of vehicle heaters and defrosters from Canada
Dear Ms. Proietto:
In your letter dated April 6, 2017, you requested a tariff classification ruling on behalf of Mobile Climate Control, Inc. Technical drawings of each product were submitted with your request.
Under consideration are five heating and defrosting units that serve to direct and distribute hot air in multiple compartments throughout the interior of transit buses. They are not used to preheat the engine of the bus, nor are they used in conjunction with the vehicle A/C systems.
The non-electric heaters and defrosters are designed for use on buses with water/glycol based heating systems. The electric heaters and defrosters are designed for use on hybrid-electric buses and are connected to the electrical system of the bus.
The Heater 24V with Temperature Sensor- Non-Electric, MCC part number T12-70334, comprises a heater core/coil, a motor-driven blower, a temperature sensor and other components encased in a steel box. This non-electric air heater is connected to the floor of the bus and is designed to provide forced cabin heat or defrost at variable speeds. It works with glycol from the vehicle engine that circulates through the heater coil and releases hot air, which is circulated by the motor-driven fan/blower throughout the bus.
The Defroster 24V- Non-Electric, MCC part number 12-60076, which is mainly used as a front defroster, consists primarily of a heat exchanger/coil and a motor-driven fan encased in a steel box. It works with glycol from the engine that circulates through the heater coil. The electric blower then pushes out the heated air to defrost and de-ice the windshield, while also providing heat to the driver’s compartment. Control of the heater/defroster system is achieved by manipulating a series of switches on the dashboard.
The applicable subheading for the Heater 24V with Temperature Sensor- Non-Electric (T12-70334) and the Defroster 24V- Non-Electric (12-60076) will be 7322.90.0015, Harmonized Tariff Schedule of the United States (HTSUS), which provides for air heaters and hot air distributors (including distributors which can also distribute fresh or conditioned air), not electrically heated, incorporating a motor-driven fan or blower, of iron or steel. The general rate of duty will be free.
The Electric Low Floor Heater 24V, MCC part number 12-70308, is encased in in a stainless steel box and consists of a blower, a heating element, a motor and other components. The heater is installed into the floor of a hybrid-electric transit bus and is connected to the bus’s electrical system for the purpose of providing heat to the passengers.
The Electric Defroster 24V, MCC part number T12-8593, consists of a blower, a heating element and other components enclosed in a steel unit. The product is installed into the dashboard of a hybrid-electric bus and connects to the bus’s electrical system. The defroster provides heat to the windshield and the driver’s compartment.
Heading 8419 provides for machinery other than of a kind used for domestic purposes, used for the treatment of materials by a process involving a change of temperature, such as heating. In this instance, the MCC part numbers 12-70308 and T12-8593 are electric apparatus used to heat public transit buses. As such, the applicable subheading for the Low Floor Heater 24V (12-70308) and the Electric Defroster 24V (T12-8593), will be 8419.89.9585, HTSUS, which provides for machinery, plant or laboratory equipment, whether or not electrically heated, for the treatment of materials by a process involving a change of temperature...: Other machinery, plant or equipment: Other: Other: Other; For other materials. The general rate of duty will be 4.2 percent ad valorem.
The Convector P90, MCC part number 22-90090, is a twin copper pipe system that operates as a heater through which the hot coolant from the engine circulates, allowing heat to generate using air as a medium to dissipate heat. It mounts to either the driver side or along the passenger side of the bus. You state in your request that the convector core has no electrical components or moving parts, and is installed with the use of clips, fittings and end caps. It works with the heated engine coolant, which is forced through the copper tube and aluminum fin coil by the engine coolant pump. The heated coolant radiates heat into the surrounding air by natural convection.
The applicable subheading for the Convector P90 (Part Number 22-90090) will be 8708.99.8180, HTSUS, which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other: Other.” The general rate of duty will be 2.5 percent ad valorem.
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 https://hts.usitc.gov/current.
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 Barbara Kaiser at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division