CLA-2-84:OT:RR:NC:N1:105
Irene Leonard
Leonard Trade Consulting, LLC
5073 E. Lighthorse Circle
Inverness, FL 34452
RE: The tariff classification of spray nozzles from Germany
Dear Ms. Leonard:
In your letter dated July 17, 2025, on behalf of your client, Greenleaf Technologies, Inc., you requested a
tariff classification ruling. Descriptive literature was provided for our review.
The items under consideration are described as Venturi-style spray nozzles, which are used for agricultural
spray booms, and allow for a variety of spray range, pattern, and distribution. The nozzles are typically used
for the application of pesticides, herbicides, and fertilizers. The Venturi-style nozzles provide application to
their target by using the Venturi-effect, a core principle of the nozzle that describes the pressure drop in a
fluid as it flows through a constricted section of a pipe or nozzle. This pressure drop can then be used to draw
in and mix a secondary fluid, such as air, into the primary stream. This process results in finer atomization
and can improve spray coverage. The nozzles are completely passive and do not incorporate any mechanical
features.
The first nozzle is the AM11004 - Nozzle AirMix Flat Fan, which is a 15mm by 22mm nozzle with a
pressure of 14.5 pounds per square inch (PSI) to 87 PSI. This nozzle has a low-pressure flat fan venturi
nozzle, two-piece design, and an air cleaning system. The droplet size is adjustable from coarse to fine
through pressure, has a wide application range, and fits in double flat fan cap or ADF-caps.
The second nozzle is the TDXLV04 - Injector Standard Poly - Red, which is a 40mm by 38mm nozzle with a
pressure of 14.5 PSI to 508 PSI. It has an injector with a cast standard bayonet and is a basic component of
the TurboDrop modular system. The device is made of chemical-resistant plastic and has two side air intake
openings.
The third nozzle is the TDXL11004 TurboDrop Standard Poly, which is a 40mm by 50mm nozzle with a
pressure of 14.5 PSI to 29 PSI. The nozzle has a multi-range injector flat jet nozzle with a plastic design. It
has a molded standard bayonet cap, variable, low-drift droplet spectrum, very large adjustable range, and is
ideal for changing application rates and drop sizes.
The fourth nozzle is the SMP8004 - Nozzle SprayMax, which is a 15mm by 11mm nozzle with a pressure of
14.5 PSI to 58 PSI. This nozzle is a standard flat jet nozzle with high precision. It has a large pressure and
volume adjustment range as well as a high wear resistance.
The fifth nozzle is the CADF Cap for SprayMax, AirMix or BPDF Nozzles, which is a 32mm by 46mm by
38mm nozzle that has a pressure up to 145 PSI. It is suitable for nozzle holders with a standard bayonet
system and can be combined with the TurboDrop injectors. The beam angle is 10 degrees in the front, 50
degrees in the rear, and has a short compact design. This device is narrower than comparable double flat jet
caps and uses a slider system for easy assembly and cleaning. While it is referred to as a “cap,” it essentially
functions as a nozzle or contains nozzles within it that are responsible for the spray pattern and application.
As you suggest in your letter, the applicable subheading for the spray nozzles (the AM11004 - Nozzle
AirMix Flat Fan, the TDXLV04 - Injector Standard Poly - Red, the TDXL11004 TurboDrop Standard Poly,
the SMP8004 - Nozzle SprayMax, and the CADF Cap for SprayMax, AirMix or BPDF Nozzles) will be
8424.90.9080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Mechanical
appliances (whether or not hand operated) for projecting, dispersing or spraying liquids or powders; fire
extinguishers, whether or not charged; spray guns and similar appliances; steam or sand blasting machines
and similar jet projecting machines; parts thereof: Parts: Other: Other.” The general rate of duty will be free.
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
8424.90.9080, 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/.
Additionally, you requested that the spray nozzles be considered for duty-free treatment under subheading
9817.00.50, HTSUS. Part 177.7 provides that rulings will not be issued in certain circumstances. Specifically,
Part 177.7(b) reads, in pertinent part: No ruling letter will be issued with respect to any issue which is
pending before the United States Court of International Trade, the United States Court of Appeals for the
Federal Circuit or any court of appeal therefrom. As such, CBP will not issue a ruling regarding the eligibility
of the quick connectors under subheading 9817.00.50, HTSUS, at this time.
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 Jason Christie at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division