CLA-2-73:OT:RR:NC:N4:410
Hugo Morelli
9241 Gallery Place
Colorado Springs, CO 80924
RE: The tariff classification of wood-burning stove with heat exchanger boiler from Italy
Dear Mr. Morelli:
In your letter dated August 6, 2025, you requested a tariff classification ruling.
The merchandise at issue is identified as Pettinger 1300 Professional with Heat Exchanger Boiler (“stove”). It
is a wood-burning stove for domestic use, which features an integrated heat exchanger boiler with plumbing
connections, enabling the stove to provide hot water. Additionally, the unit includes a built-in electric oven
light, which serves solely as a visual aid and does not affect the heating function. Constructed primarily of
steel with stainless steel exterior, the stove measures approximately 1300 mm wide × 850 mm high × 600
mm deep.
In your submission, you suggest that the subject wood-burning cooking stove with a space heating boiler is
correctly classified in subheading 8403.10.0000, Harmonized Tariff Schedule of the United States (HTSUS),
which provides for “Central heating boilers (other than those of heading 8402) and parts thereof: Boilers.”
We disagree. In understanding the language of the HTSUS, the Harmonized Commodity Description and
Coding System Explanatory Notes may be utilized. The Explanatory Notes for heading 8403 excludes stoves
with subsidiary boilers. As such, the subject cooking stove is not classified in heading 8403.
The applicable subheading for the Pettinger 1300 Professional with Heat Exchanger Boiler will be
7321.19.0080, HTSUS, which provides for other cooking appliances and plate warmers including appliances
for solid fuel, other than portable, of iron (other than cast iron) or steel. The rate of duty is free.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter
99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as
products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 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. 9903.81.90, in addition to subheading 7321.19.0080, 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 of the European
Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15
percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General
duty rate. 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., 9903.01.33, in addition to subheading
7321.19.0080, 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 Michael Chen at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division