CLA-2-73:OT:RR:NC:N5:121
Christian Galley
Tubmarine
Unit 1 The Old Sawmills, Middlemarsh
Sherborne DT9 5QW
United Kingdom
RE: The tariff classification of two steel soaking tubs from the United Kingdom
Dear Mr. Galley:
In your letter dated June 4, 2025, you requested a tariff classification ruling for two steel soaking systems.
The first article under consideration is described as a Wood-Fired Stainless Steel Water Heating and Soaking
System. It is a fully insulated stainless steel tub with a fixed internal heating system. This freestanding
outdoor soaking tub is made of 316/304 stainless steel. The water in the tub is heated via an internal, fixed
wood-burning combustion chamber. According to your submitted documentation, the system includes an
insulated steel tub, log feed, chimney, insulated water jacket, and wood cladding. It has no jets or digital
controls.
The second article under consideration is described as an Electric Stainless Steel Water Heating and Soaking
System. It is a fully insulated stainless steel tub with a fixed internal heating system. This freestanding
outdoor soaking tub is made of 316/304 stainless steel. According to your submitted documentation, the
system includes an insulated steel tub, basic digital control box for temperature regulation, an electric
resistance heater, circulation pump, and wood cladding. It does not include any jets, massage systems, or spa
features.
In your submission, you suggest that the subject wood-fired heating and soaking system and the electric
heating and soaking system are classifiable under subheading 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.” We disagree. Heading 8419 provides for machinery designed to submit materials to a heating or
cooling process to cause a simple change of temperature, or to cause a transformation of materials using a
change in temperature. Based on the literature provided, both units are not used for treating materials, but
principally used as soaking tubs for bathing, personal cleansing, or relaxation. Taking this into consideration,
classification of the wood-fired heating and soaking system and the electric heating and soaking system in
heading 8419, HTSUS, is precluded.
The applicable subheading for the Wood-Fired Stainless Steel Water Heating and Soaking System and the E
lectric Stainless Steel Water Heating and Soaking System will be 7324.29.0000, HTSUS, which provides for
Sanitary ware and parts thereof, of iron of steel: Baths: Other. The 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 of 25% for derivative iron or steel products of the United Kingdom are
reflected in Chapter 99, headings 9903.81.96, 9903.81.97, and 9903.81.98. Products provided by heading
9903.81.98, as well as products of Chapter 73 provided by 9903.81.96 and 9903.81.97 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. 9903.81.97, in addition to subheading 7324.29.0000,
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.
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,
including United Kingdom, will be subject to an additional 10 percent ad valorem rate of duty. For products
covered by heading 9903.81.97, the reciprocal duty applies to the non-steel content of the merchandise. 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 7324.29.0000, 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 Jennifer Jameson at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division