CLA-2-85:OT:RR:NC:N4:415
Mr. George R. Tuttle III, Esq.
Tuttle Law Offices
3950 Civic Center Drive
San Rafael, CA 94903
RE: The tariff classification of a hot and cold water dispenser from China.
Dear Mr. Tuttle:
In your letter dated November 30, 2022, you requested a tariff classification ruling on behalf of your client, Strix Ltd.
Images and product information were submitted in lieu of a sample.
The merchandise under consideration is described as the “Aurora Hot & Chilled Water Dispenser.” This appliance delivers hot and chilled water for beverages on demand using a touch display. It provides heated water at 40° C, 60° C, 80° C, 90° C, 95° C, and boiling water at 100° C. The heating is produced through an instant flow heater. Additionally, the product provides chilled water at 8 to12° C. The cooling is produced through a thermoelectric cooler using the Peltier effect. A fan is combined with the chiller to remove the heat generated from the hot side of the Peltier component. The dispenser features a removable water tank and filter. It is designed for domestic use and is intended to be placed on a countertop. It will be imported completely assembled and packaged for retail sale.
We note that this water dispenser is similar to the ones which were addressed in HQ H322878, dated August 23, 2022. Therefore, this would also be classified within heading 8516 utilizing General Rule of Interpretation 3(c).
The applicable subheading for the “Aurora Hot & Chilled Water Dispenser” will be 8516.79.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "[e]lectric instantaneous or storage water heaters and immersion heaters; electric space heating apparatus and soil heating apparatus; electrothermic hairdressing apparatus (for example, hair dryers, hair curlers, curling tong heaters) and hand dryers; electric flatirons; other electrothermic appliances of a kind used for domestic purposes; electric heating resistors, other than those of heading 8545; parts thereof: [o]ther electrothermic appliances: [o]ther.” The column one, general rate of duty is 2.7 percent.
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 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 Kristopher Burton at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division