CLA-2-84:OT:RR:NC:N1:102
Ernie Ubriaco
Customs Trade Services Inc.
21 Pierina Court
Vaughan, ON L4H2R8
Canada
RE: The tariff classification of a chiller from Canada
Dear Mr. Ubriaco:
In your letter dated August 27, 2025, you requested a tariff classification ruling, on behalf of your client,
Epsilon Industries Inc. Descriptive information was provided with your submission.
The product at issue is referred to as a Modular Section 8 Chiller, item number CVHF130R-514A. The low
temperature centrifugal chiller consists of a steel frame that incorporates various valves, flow switches,
temperature indicators, a control pan, a condenser, a compressor and an evaporator. Once installed into the
base of a modular central utility plant, the chiller completes cooling cycles that utilize refrigerant to lower the
temperature of water used by other sections of the plant.
In your letter, you suggest the chiller is classified as a part within subheading 8419.90.9580, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for parts of machinery for the treatment of
materials by a process involving a change of temperature. We disagree. Note 2 to Section XVI states that
subject to note 1 to this section, note 1 to chapter 84, and note 1 to chapter 85, parts of machines (not being
parts of the articles of heading 8484, 8544, 8545, 8546 or 8547) are to be classified according to the
following rules:
(a) Parts which are goods included in any of the headings of chapter 84 or 85 (other than headings 8409,
8431, 8448, 8466, 8473, 8487, 8503, 8522, 8529, 8538 and 8548) are in all cases to be classified in their
respective headings;
(b) Other parts, if suitable for use solely or principally with a particular kind of machine, or with a number of
machines of the same heading (including a machine of heading 8479 or 8543) are to be classified with the
machines of that kind or in heading 8409, 8431, 8448, 8466, 8473, 8503, 8522, 8529 or 8538 as appropriate.
However, parts which are equally suitable for use principally with the goods of headings 8517 and 8525 to
8528 are to be classified in heading 8517, and parts which are suitable for use solely or principally with the
goods of heading 8524 are to be classified in heading 8529.
Note 2(a) to Section XVI, HTSUS, eliminates classification as a part within heading 8419, as the chiller,
which completes refrigeration cycles to lower the temperatures of water, meets the terms of heading 8418.
Heading 8418 specifically provides for machinery that refrigerates or freezes.
As such, the applicable subheading for the chiller will be 8418.69.0140, HTSUS, which provides for
Refrigerators, freezers and other refrigerating or freezing equipment, electric or other; heat pumps, other than
the air conditioning machines of heading 8415; parts thereof: Other refrigerating or freezing equipment; heat
pumps: Other: Centrifugal liquid chilling refrigerating units. The general rate of duty will be Free.
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 35 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 8418.69.0140, 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 8418.69.0140, 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 of Canada are not
subject to reciprocal tariffs. 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 8418.69.0140, 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)
Denise Faingar
Acting Director
National Commodity Specialist Division