CLA-2-84:OT:RR:NC:N1:102
Sheri Lawson
Willson International Inc.
160 Wales Avenue, Suite 100
Tonawanda, NY 14150
RE: The tariff classification of air conditioner housings from Canada
Dear Ms. Lawson:
In your letter dated September 12, 2025, you requested a tariff classification ruling on behalf of your client,
Razor Contract Mfg. Ltd. Descriptive information was provided with your submission.
The items at issue are referred to as air conditioner housings, item numbers ACU-802, ACU-804, COOL-10
and ACU-808. The rectangular configured housings are frames that feature circular openings for fans, square
openings for electrical panels, bores for screws or bolts, center cross frames, and a bottom platform that
allows for the installation of cooling components, such as a condenser and a compressor. The housings will
be used in air conditioning systems that change the temperature and humidity levels within airplanes while
stationary on the tarmac.
The applicable subheading for the air conditioner housings will be 8415.90.4000, 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; parts thereof: Parts: Chassis, chassis bases and outer
cabinets. The general rate of duty will be 1.4 percent ad valorem.
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. 9903.81.91, in addition to subheading 8415.90.4000, 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.
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. For
products covered by heading 9903.81.91 this additional duty applies to the non-steel content of the
merchandise. At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.10, in
addition to subheading 8415.90.4000, 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 8415.90.4000, 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 8415.90.4000, 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