CLA-2-84:OT:RR:NC:N1:102
Sunday Ojajuni
Sunday Omogoriola Ojajuni DBA Elyon Customs Broker
93 W Rainbow Ridge Circle
Spring, TX 77381
RE: The tariff classification of a fan wall module from China
Dear Mr. Ojajuni:
In your letter dated August 28, 2025, you requested a tariff classification ruling on behalf of your client,
DeepCoolAI Inc. Descriptive information was provided with your submission.
The product at issue is a fan wall module (model number DBAWM-210-7). The module, which is part of a
closed loop system, is a framed structure that coordinates the cooling, purifying, and dehumidifying of air
within spaces of commercial data centers and other types of industrial environments. The cooling and
dehumidifying processes completed within the module occur when electrical fans draw in air and the air
passes through copper tube heat exchanger units with aluminum fins to condense water vapor into liquid.
Afterwards, the condensate is drained, and the cooled air is purified and subsequently reheated. The heated
water is returned to a remote chiller equipped with a condenser, in which water is rechilled to 27 degrees
Celsius. The cycle is repeated when the chiller returns low temperature water to the fan wall module through
supply and return pipelines. During seasons with low temperatures, the system also uses outdoor air to
indirectly cool return water, reducing the energy consumption of the separately located compressor. The fan
wall module will be imported in a single shipment but unassembled due to its size.
In your letter, you suggest classifying the module within subheading 8415.83.0060, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for Air conditioning machines, comprising a
motor-driven fan and elements for changing the temperature and humidity, including those machines in
which the humidity cannot be separately regulated; not incorporating a refrigerating unit; Other, except parts;
Not incorporating a refrigerating unit; Heat exchangers including condensing units; Condensing units;
Exceeding 17.58 kW per hour. We disagree, as the module functions as an indoor unit of an air conditioning
system that changes temperature and humidity levels of spaces. Indoor units of air conditioning systems are
classified as parts within subheading 8415.90.
Pursuant to General Rule of Interpretation 2(a), the applicable subheading for the unassembled fan wall
module will be 8415.90.8085, HTSUS, which provides for Air conditioning machines, comprising a
motor-driven fan and elements for changing the temperature and humidity, including those machines in
which the humidity cannot be separately regulated; parts thereof: Parts: Other: Other: Other. The general rate
of duty will be 1.4 percent ad valorem.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.24, in addition
to subheading 8415.90.8085, HTSUS, listed above.
On March 12, 2025, Presidential proclamation 10895 imposed additional tariffs on certain derivative
aluminum products. Additional duties for derivative aluminum products of 50 percent are reflected in
Chapter 99, headings 9903.85.04, 9903.85.07, and 9903.85.08. Products provided by heading 9903.85.08, as
well as products of Chapter 76 provided by 9903.85.04 and 9903.85.07, will be subject to a duty of 50
percent upon the value of the aluminum content. At the time of entry, you must report the Chapter 99 heading
applicable to your product classification, i.e., 9903.85.08, in addition to subheading 8415.90.8085, HTSUS.
Derivative aluminum articles processed in another country from aluminum articles that were smelted and cast
in the United States, provided for in heading 9903.85.09, 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 China will be
subject to an additional ad valorem rate of duty of 10 percent. For products covered by heading 9903.85.08
this additional duty applies to the non-aluminum content of the merchandise. 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 8415.90.8085, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8415.90.8085, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15,
in addition to subheading 8415.90.8085, 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
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division