CLA-2-85:OT:RR:NC:N4:462
Stacy Han
S & H Customs Broker, Inc.
13810 Cerritos Corporate Drive, Suite B Cerritos, CA 90703
RE: The tariff classification of electric heat pump water heaters from South Korea.
Dear Ms. Han:
In your letter dated February 13, 2025, you requested a tariff classification ruling on behalf of your client, Navien America, Inc.
Images were provided in lieu of samples.
The products under consideration are all described as electric heat pump water heaters. Your submission lists three model numbers, PCW350S-50, PCW350S-65 and PCW350S-80. The difference between these three versions is their storage capacity, 50, 65, and 80 gallons. They are residential storage water heaters that incorporate both standard electric heating elements and a heat pump system that extracts heat from the air, or in some cases the ground, and transfers that heat into the water in the tank. Your correspondence indicated that the heat pumps aid in the overall efficiency of the water heater, but the heating elements are needed to satisfy all of the end user's demands. We hold the opinion that this product is most accurately described in heading 8516.
The applicable subheading for these electric heat pump water heaters, model numbers PCW350S-50, PCW350S-65 and PCW350S-80, will be 8516.10.0040, 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: [e]lectric instantaneous or storage water heaters and immersion heaters: [s]torage water heaters. The general rate of duty is 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 at https://hts.usitc.gov/current.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request.This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1).This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect.In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR 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 above, please contact National Import Specialist Sandra Sary at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division