CLA-2-84:OT:RR:NC:N1:102
Jacques Fiorella
Industrial Equipment and Solutions of Florida LLC
3741 Mayo Circle
Ormond Beach, FL 32174
RE: The tariff classification of air dryers from South Korea
Dear Mr. Fiorella:
In your letter dated June 7, 2025, you requested a tariff classification ruling.
The products in question are mechanical air dryers, specifically the AW model series. Each dryer features an
inlet that receives compressed air and two notched pieces that incorporate shafts. In use, the two aluminum
pieces are rotated to correspond to the outer diameter of the cable jacket. Once the cable jacket is inserted and
enclosed between the notches, compressed air travels through the orifices to be concentrated onto the cable
jacket for the purpose of removing moisture. The air dryers, which are imported in a package of three, are
designed to be mounted on a stand or screwed onto the wall of a trough.
In your request, you suggest that the subject mechanical air dryer is classifiable under subheading
8419.33.5000, 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: Dryers: Lyophilisation apparatus, freeze
drying units and spray dryers: Other. We disagree. The subject mechanical air dryer does not use a change
in temperature to dry wire or cable jackets. Rather, it directs compressed air to remove residual water from the
jacket during manufacturing. As such, heading 8419 is precluded from consideration. Instead, the air dryers,
which are designed to deliver pressurized air, are classified within heading 8414, as this heading provides for
machines that circulate or deliver compressed air and gases.
The applicable subheading for the individual mechanical air dryers will be 8414.80.9000, HTSUS, which
provides for Air or vacuum pumps, air or other gas compressors and fans; ventilating or recycling hoods
incorporating a fan, whether or not fitted with filters; gas-tight biological safety cabinets, whether or not
fitted with filters; parts thereof: Other, except parts: Other. The general rate of duty will be 3.7 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
8414.80.9000, 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 Sandra Martinez at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division