CLA-2-84:OT:RR:NC:N1:103
Hendrik Thieme
Eberspächer Gruppe GmbH & Co. KG
Eberspächerstrasse 24
Esslingen 73730
Germany
RE: The tariff classification of the Hydronic S3 and Airtronic S3/M3 from Poland
Dear Mr. Thieme:
In your letter dated May 19, 2025, you requested a tariff classification ruling on behalf of Eberspächer
Climate Control Systems USA Inc.
The first item under consideration is identified as the Eberspacher Hydronic S3 and is described as a
fuel-operated preheater for vehicle coolant. It is marketed for use in motorized vehicles, marine vessels,
heavy machinery, etc., and designed to operate independently from the vehicle’s main engine.
On its website, Eberspacher describes the Hydronic S3 as a sealed assembly whose main components include
a control unit, flame sensor, water sensor, combustion chamber, and convector housing, which is described as
an outer housing that surrounds the combustion chamber. Heat is generated by burning a fuel mixture inside
the combustion chamber. The vehicle coolant enters the unit and flows between the convector housing and
combustion chamber where it is heated. The heated fluid can then be used to pre-heat an engine, routed to a
boiler to heat water, or sent to convectors inside a vehicle for space heating. The ultimate configuration will
depend on the customer’s requirements.
There are multiple versions of the Hydronic S3 available, including the B4E, B5E, D4E, D5E, D5L, and
D6L. Their functions are identical and only differ in compatible fuel type (e.g., gasoline or diesel) and
heating performance (ranging from 1.3 kW to 5.6 kW).
The applicable subheading for the Eberspacher Hydronic S3 will be 8419.89.9585, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for “Machinery, plant or laboratory equipment,
whether or not electrically heated (excluding furnaces, ovens and other equipment of heading 8514), for the
treatment of materials by a process involving a change of temperature such as heating, cooking, roasting,
distilling, rectifying, sterilizing, pasteurizing, steaming, drying, evaporating, vaporizing, condensing or
cooling, other than machinery or plant of a kind used for domestic purposes; instantaneous or storage water
heaters, nonelectric; parts thereof: Other machinery, plant or equipment: Other: Other: Other: Other: For
other materials.” The general rate of duty will be 4.2 percent ad valorem.
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
8419.89.9585, HTSUS, listed above.
The second item under consideration is described as the Eberspacher Airtronic S3/M3 air heater. It is a
gasoline or diesel fueled air heater incorporating an electric-driven fan, a combustion chamber, and a heat
exchanger. The heater is designed to circulate warm air in commercial and special vehicles. We note that this
product is similar to the Airtronic air heater ruled upon in N029080, dated June 17, 2008.
The applicable subheading for the Eberspacher Airtronic S3/M3 air heater will be 7322.90.0015, 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, and parts thereof, of
iron or steel: Other, including parts… Air heaters, not electrically heated, incorporating a motor-driven fan or
blower.” The general rate of duty will be free.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 25 percent are reflected in Chapter
99, headings 9903.81.89 and 9903.81.90. Products provided by heading 9903.81.91 will be subject to a duty
of 25 percent upon the value of the steel content. At the time of entry, you must report the Chapter 99
heading applicable to your product classification, i.e. 9903.81.90, in addition to subheading 7322.90.0015,
HTSUS. Derivative iron or steel products processed in another country from steel articles melted and poured
in the United States, provided for in heading 9903.81.92, are not subject to the additional ad valorem duties.
Please note that derivative steel products admitted to a U.S. foreign trade zone under “privileged foreign
status” before March 12, 2025, and entered for consumption on or after March 12, 2025, may be subject to
additional duties under heading 9903.81.93, HTSUS.
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. Your product falls within an excepted
subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.33, in addition to subheading 7322.90.0015, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 Paul Huang at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division