CLA-2-84:OT:RR:NC:N1:105
Jason Banks
M-Pack
1293 SW Briarwood Dr
Port St. Lucie, FL 34986
RE: The tariff classification of the Miniline bottler from Italy
Dear Mr. Banks:
In your letter dated September 15, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The item under consideration is described as the Miniline bottler, which is a compact, modular perfume
filling, bottling and packaging system used for small to medium scale production runs. The device’s primary
function is to fill the bottles with liquid perfume and then seal them with caps of various shapes and sizes.
The system has a main aluminum structure, 16-station rotary star wheels for bottle step movement, and a
manual bottle infeed. Motion is operated pneumatically and managed by an electronic system which
stimulates a series of mechanical cams. The control system is contained in a pulpit connected closely to the
main structure of the machine. The electric motor and control panel are also attached to the same structure.
The Miniline bottler is fitted with a filling station made by filling pistons of 30ml each, a pressing station, a
screw tightening station, and a crimping station. The device measures 74.5cm in length by 61cm in width by
160cm in height and weighs 100kg.
The applicable subheading for the Miniline bottler will be 8422.30.9140, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for “Dishwashing machines; machinery for cleaning or drying
bottles or other containers; machinery for filling, closing, sealing or labeling bottles, cans, boxes, bags or
other containers; machinery for capsuling bottles, jars, tubes and similar containers; other packing or
wrapping machinery (including heat-shrink wrapping machinery); machinery for aerating beverages; parts
thereof: Machinery for filling, closing, sealing or labeling bottles, cans, boxes, bags or other containers;
machinery for capsuling bottles, jars, tubes and similar containers; machinery for aerating beverages: Other:
Other: Machinery for filling, closing, sealing, capsuling or labeling bottles, cans or similar containers:
Machines for filling, whether or not capable of performing other operations: Other.” The general rate of duty
will be free.
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. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.02.20, in addition to subheading 8422.30.9140, 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
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division