CLA-2-84:OT:RR:NC:N1:105
Aaron Applebaum
Sidley Austin LLP
1501 K St., N.W.
Washington, DC 20005
RE: The tariff classification of snow machines from Canada
Dear Mr. Applebaum:
In your letter dated September 30, 2025, on behalf of your client, Snow Economics Inc., you requested a
tariff classification ruling. Descriptive literature was provided for our review.
The items under consideration are described as snowmaking systems, which include five Snowgun models
(the Impulse R5, SV14, Phazer, Impulse R4, and Volt) and two Snow Fan models (the Diablo and Halo V2).
The items are used by ski resorts to supplement natural snowfall and extend their operating seasons by
creating a consistent snow base. The Snowguns work by spraying high-pressure water and compressed air
(supplied by a separate compressor) from the unit. The air breaks the water into droplets, which freeze as
they fall through the air into a fine mist. The Snowguns incorporate specific technologies designed to assist
with snowmaking at colder temperatures, with minimal air consumption, as well as at higher temperatures.
The Snowguns have a minimum water pressure of 200 pounds per square inch (PSI) and have a minimum air
pressure of 85 PSI. The combination of water and air pressure allows the Snowguns to project (or “throw”)
snow 30 to 125 feet into the air. The Snow Fans are similar to the Snowguns but have a built-in compressor.
The air and water are mixed in the barrel, and the fan propels the droplets into the air. The Snow Fans can
project snow up to 250 feet.
The Snow Fans and Snowguns are imported together with parts and components that form the finished
snowmaking systems, including hydrants, electrical control panels, hoses, and mounting structures (e.g.,
towers, sleds, and/or trailside booms). The Snowmaking Systems are imported unassembled. Following
importation, the Snow Fans and Snowguns are assembled with the parts and components with which they are
imported, and the completed system is then connected to a water source.
In your letter, you suggest the applicable subheading for the snowmaking systems to be 8424.30.9000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Mechanical appliances
(whether or not hand operated) for projecting, dispersing or spraying liquids or powders; fire extinguishers,
whether or not charged; spray guns and similar appliances; steam or sand blasting machines and similar jet
projecting machines; parts thereof: Steam or sand blasting machines and similar jet projecting machines:
Other.” We disagree. While the snowmaking systems are considered projecting and dispersing devices of
heading 8424, we do not believe they are akin to steam or sand blasting machines or other similar jet
projecting machines. The machines are not designed to be directed at an object for the purpose of cleaning it
or removing material with a high rate of pressure. Instead, the snowmaking machines spray the water into the
air for the purpose of generating snow, which falls on the designated area at a low rate of speed. While the
snow systems do direct the snow to a certain location, the snow does not reach the slope at a high velocity.
Additionally, the compressors are used to force air into the system to break the water droplets into finer
droplets that are easier to freeze and are not designed to increase the pressure of the droplets. Ultimately, the
snowmaking application would be provided for later in heading 8424.
Accordingly, the applicable subheading for the snowmaking systems including the Snowgun models (the
Impulse R5, SV14, Phazer, Impulse R4, and Volt) and Snow Fan models (the Diablo and Halo V2) will be
8424.89.9000, HTSUS, which provides for “Mechanical appliances (whether or not hand operated) for
projecting, dispersing or spraying liquids or powders; fire extinguishers, whether or not charged; spray guns
and similar appliances; steam or sand blasting machines and similar jet projecting machines; parts thereof:
Other appliances: Other.” The general rate of duty will be 1.8 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 8424.89.9000, 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.
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 8424.89.9000, 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.
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 headings 9903.81.91 and 9903.85.08 this additional duty applies to the non-steel and
non-aluminum 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 8424.89.9000, 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 8424.89.9000, 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 8424.89.9000, 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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division