CLA-2-84:OT:RR:NC:N1:105
Jun Ma
J&J Global LLC
12121 N Stemmons Fwy, Suite 100
Dallas, TX 75234
RE: The tariff classification of sprayers from China
Dear Mr. Ma:
In your letter dated May 6, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The first item under consideration is described as a 1-gallon handheld sprayer (SKU 307001G) consisting of
a polyethylene tank combined with a hand-operated pump, a hose, and a trigger activated spraying wand. It
features carrying straps that enable a user to hold it in their hand or over their shoulder. The sprayer is
designed to spray water, water-based fertilizers, herbicides, pesticides, and sealers. To use the sprayer, a user
first fills the plastic tank with liquid (water, fertilizer, pesticide, etc.) then pumps the tank with a manually
operated handle to increase pressure, and then depresses the trigger on the wand to spray the liquid held
within the tank. The sprayer includes different nozzles that can be affixed to the end of the spraying wand,
allowing a user to select the type of spray pattern they wish to utilize.
The second item under consideration is described as a 2-gallon handheld sprayer (SKU 307002G) consisting
of a polyethylene tank combined with a hand-operated pump, a hose, and a trigger activated spraying wand.
It features carrying straps that enable a user to hold it in their hand or over their shoulder. The sprayer is
designed to spray water, water-based fertilizers, herbicides, pesticides, and sealers. To use the sprayer, a user
first fills the plastic tank with liquid (water, fertilizer, pesticide, etc.) then pumps the tank with a manually
operated handle to increase pressure, and then depresses the trigger on the wand to spray the liquid held
within the tank. The sprayer includes different nozzles that can be affixed to the end of the spraying wand,
allowing a user to select the type of spray pattern they wish to utilize.
The third item under consideration is described as a 3-gallon handheld sprayer (SKU 307003G) consisting of
a polyethylene tank combined with a hand-operated pump, a hose, and a trigger activated spraying wand. It
features carrying straps that enable a user to hold it in their hand or over their shoulder. The sprayer is
designed to spray water, water-based fertilizers, herbicides, pesticides, and sealers. To use the sprayer, a user
first fills the plastic tank with liquid (water, fertilizer, pesticide, etc.) then pumps the tank with a manually
operated handle to increase pressure, and then depresses the trigger on the wand to spray the liquid held
within the tank. The sprayer includes different nozzles that can be affixed to the end of the spraying wand,
allowing a user to select the type of spray pattern they wish to utilize.
The fourth item under consideration is described as a 4-gallon backpack sprayer (SKU 307004G) consisting
of a polyethylene tank combined with a hand-operated pump, a hose, and a trigger activated spraying wand.
The sprayer features two shoulder straps that enable a user to wear it on their back. It is designed to spray
water, water-based fertilizers, herbicides, pesticides, and sealers. To use the sprayer, a user first fills the
plastic tank with liquid (water, fertilizer, pesticide, etc.) then pumps the tank with a manually operated lever
to increase pressure, and then depresses the trigger on the wand to spray the liquid held within the tank. The
sprayer includes different nozzles that can be affixed to the end of the spraying wand, allowing a user to
select the type of spray pattern they wish to utilize.
The applicable subheading for the 1-gallon handheld sprayer (SKU 307001G), 2-gallon handheld sprayer
(SKU 307002G), 3-gallon handheld sprayer (SKU 307003G), and 4-gallon backpack sprayer (SKU
307004G) will be 8424.41.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides
for “Mechanical appliances (whether or not hand operated) for projecting, dispersing or spraying liquids or
powders; fire extinguishers, whether or not charged; spray guns and similar appliances; steam or sand
blasting machines and similar jet projecting machines; parts thereof: Agricultural or horticultural sprayers:
Portable sprayers: Other.” The general rate of duty will be 2.4 percent ad valorem.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.24, in addition
to subheading 8424.41.9000, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading
8424.41.9000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8424.41.9000, 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 9903.88.03 in
addition to subheading 8424.41.9000, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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/.
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 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 Jason Christie at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division