CLA-2-84:OT:RR:NC:N1:104
PJ Trainham
Bay Brokerage Inc.
42832 State Route 12
Alexandria Bay, NY 13622
RE: The tariff classification of a bladder expansion tank from Canada
Dear Mr. Trainham:
In your letter dated June 19, 2025, on behalf of your client, Armstrong Fluid Technology, you requested a
tariff classification ruling.
The subject HVAC bladder expansion tank is a type of vessel used in closed-loop hydronic (water) heating
and cooling systems. Resembling a small metal container, the expansion tank’s main function is to absorb or
buffer excess water pressure caused by thermal expansion of the water. The tank’s interior provides the space
for excess pressure and is divided into two by a rubber diaphragm or bladder; one side is connected to the
pipe work of the hydronic system and thus contains water; the other side contains air under pressure. As
water heats up and expands, it pushes against the diaphragm, compressing the air on the other side. When the
water cools and contracts, the compressed air pushes the water back into the system, maintaining pressure.
You claim that the HVAC expansion tank is properly classified in subheading 8479.89.9565, Harmonized
Tariff Schedule of the United States (HTSUS), as a hydraulic accumulator. We disagree. Hydraulic
accumulators are energy storage components in hydraulic systems. They are designed to store energy in the
form of pressurized hydraulic fluid -- not water -- for later use. While some types of hydraulic accumulators
utilize a bladder or diaphragm to separate the pressurized gas from the hydraulic fluid, others employ an
internal piston for this function. Furthermore, hydraulic accumulators are used not only for controlling and
maintaining pressure, but for other purposes such as absorbing shocks, dampening vibrations, supplementing
pump flow, and providing emergency power.
The applicable subheading for the HVAC bladder expansion tank will be 8479.89.9599, HTSUS, which
provides machines and mechanical appliances having individual functions, not specified or included
elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other. The
general rate of duty will be 2.5 percent ad valorem.
Products of Canada as provided by heading 9903.01.10 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(j), HTSUS, other than products classifiable under headings 9903.01.11, 9903.01.12, 9903.01.13,
9903.01.14, and 9903.01.15, HTSUS, will be subject to an additional 25 percent ad valorem rate of duty. At
the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.10, in addition to
subheading 8479.89.9599, HTSUS, listed above. Articles that are entered free of duty under the terms of
general note 11 to the HTSUS (U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set
forth in subchapter XXIII of Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be
subject to the additional ad valorem duties provided for in heading 9903.01.10. If your product is entered
duty free as originating under the USMCA, you must report heading 9903.01.14, HTSUS, in addition to
subheading 8479.89.9599, 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., 9903.01.26, in addition to subheading 8479.89.9599, 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 Arthur Purcell at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division