CLA-2-85:OT:RR:NC:N4 410
Daniel Morgan
Columbia Products
1622 Browning
Irvine, CA 92606
RE: The tariff classification of heating elements from China
Dear Mr. Morgan:
In your letter dated June 6, 2025, you requested a tariff classification ruling.
The products under consideration are identified as Item 1, Heating Elements and Item 2, Scoops.
The classification of the Scoops is addressed under separate cover in ruling N350665.
Item 1 covers Models 1100, 1500, 1100N and 1500N. Each heating element in all models consists of a type
304 stainless steel enclosure and a U-shaped heating element rod. Models 1100 and 1500 feature an
adjustable dial that allows the user to increase the temperature setting by turning the dial clockwise and an
on/off light indicator shows when the unit is heating.
All models have a 6 feet 3-wire grounded cord with plug, and a 1-inch standard NPT male thread for
through-the-side tank installation in knife sterilizers with a 1-inch NPT threaded female flange. These models
also come with a stainless steel nut and rubber washer for installation in knife sterilizers with a 1.25 inches
hole.
In your submission, you proposed classification of the heating elements in subheading 8516.10, HTSUS, as
storage water heaters and immersion heaters.
We agree.
The applicable subheading for the heating elements will be 8516.10.0080, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for other instantaneous electric water heaters and immersion heaters.
The rate of duty is free.
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 8516.10.0080, 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
8516.10.0080, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8516.10.0080, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15,
in addition to subheading 8516.10.0080, HTSUS, listed above.
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.
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 on World Wide Web at https://hts.usitc.gov/current.
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 Michael Chen at [email protected]..
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division