CLA-2-90:OT:RR:NC:N1:105
Amirreza Amighi
Mazlite
24 Bobwhite Crescent
Toronto, Ontario M2L 2E1
Canada
RE: The tariff classification of the Mazlite System from Canada
Dear Ms. Amighi:
In your letter dated September 4, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The item under consideration is described as the Mazlite System, which is an imaging-based instrument
designed for monitoring spray patterns in automotive paint and coating applications. The system consists of
an imaging sensor unit (captures high-resolution images of sprays in hazardous environments), purge
controller (ensures safe operation in explosive or hazardous paint shop locations), and server/controller (runs
proprietary software for analysis, process monitoring, and closed-loop control between plant robotic systems
and the sensor). The system provides analytical imaging data for customers, enabling automated process
optimization and quality control in industrial paint and coating environments.
The system captures optical images of atomized paint or coating spray prior to the coating application and
analyzes the results for quality assurance. The images are processed using proprietary software to measure
spray shape, coverage, and uniformity. The results are transmitted to plant control systems, enabling
automated process adjustments and reporting to customers. In addition to the raw data, the AI-analytics
provide the user a “GO” or “NO GO” response. The system is designed for use in automotive paint spray
booths and industrial coating plants. The instrument is powered by standard electrical supply (110–240V
AC).
In your letter, you suggest the applicable subheading for the Mazlite System to be 9027.50.4060, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for “Instruments and apparatus for physical or
chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke analysis
apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion, surface
tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound or light
(including exposure meters); microtomes; parts and accessories thereof: Other instruments and apparatus
using optical radiations (ultraviolet, visible, infrared): Other: Electrical: Other.” We disagree. The Mazlite
System is not designed to provide an analysis of light. Instead, it is utilizing optical elements to scan high
resolution images, which are then used to determine whether the paint quality is satisfactory. Therefore, we
find the system to be more of a checking device than a light analysis device. Thus, heading 9027, HTSUS, is
excluded from consideration.
In your letter, you further suggest the applicable subheading to be 9031.80.80, HTSUS, which provides for
“Measuring or checking instruments, appliances and machines, not specified or included elsewhere in this
chapter; profile projectors; parts and accessories thereof: Other instruments, appliances and machines: Other:
Other.” The Mazlite System utilizes an optical camera system in order to provide the high-resolution images
used by the system. The camera optimizes the quality control in industrial paint and coating environments
and is essential for the system to operate. Since the system uses this optical element, the Mazlite System will
be classified earlier in the heading.
Accordingly, the applicable subheading for the Mazlite System will be 9031.49.9000, HTSUS, which
provides for “Measuring or checking instruments, appliances and machines, not specified or included
elsewhere in this chapter; profile projectors; parts and accessories thereof: Other optical instruments and
appliances: Other: Other.” 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 9031.49.9000, 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 9031.49.9000, 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 9031.49.9000, 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 Jason Christie at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division