CLA-2-84:OT:RR:NC:N1:104
Sunday Ojajuni
Sunday Omogoriola Ojajuni, DBA Elyon Customs Broker
93 W Rainbow Ridge Cir
Spring, TX 77381
RE: The tariff classification of a cold storage module from China
Dear Ms. Ojajuni:
In your letter dated October 9, 2025, on behalf of your client, DeepCoolAI Inc., you requested a tariff
classification ruling.
The product in question is a containerized Cold Storage Module, which is designed to be integrated into an
industrial cooling system known as the High-Efficiency Maglev Integrated Cooling Station (Cooling Station).
The Cooling Station, not imported with the Cold Storage Module, employs magnetic levitation (maglev)
technology to maximize energy efficiency. The Cooling Station chills water with an aircooled maglev chiller,
circulates the chilled water to terminal loads, and then uses the Cold Storage Module to store, buffer, and
supply emergency chilled water (using a connected pump) through piping to briefly (5 minutes) maintain
chilled-water circulation during a chiller unit power failure. Neither the water chiller unit nor the pipe module
of the Cooling Station will be imported with the Cold Storage Module.
The Cold Storage Module is comprised of several mechanical, electrical, and other components which are
interconnected and function together. The primary components include: (1) a steel, insulated horizontal cold
storage tank with nozzles, top exhaust and bottom drain, which acts as the thermal reservoir providing chilled
water during power loss and stabilizing return-water temperature; (2) a degassing unit, consisting of a water
pump, atmospheric pressure tank, vacuum degassing tank, PLC controller, and automatic control valves,
which keeps the chilled-water circuit stable and air-free to ensure continuous flow and protects pumps and
tanks from pressure fluctuations; and (3) a chilled water pump which is connected to the tank and discharges
and delivers the chilled water when needed during a power failure. Other components of the Cold Storage
Module include a dosing device which integrates online monitoring of PH and conductivity, supports timed
automatic dosing control of corrosion and scale inhibitors and bactericides, a dual power cabinet, an inverter
cabinet for high-density power distribution and equipment monitoring, a cooling module distribution cabinet,
a wall-mounted AC unit for cabinet cooling various control and power cabinets, network equipment, security
equipment, and a group and unit control cabinets.
You suggest that in accordance with Note 2(b) to Section XVI, the Cold Storage Module is classified within
subheading 8418.99.8060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for
Refrigerators, freezers and other refrigerating or freezing equipment, electric or other; heat pumps, other than
the air conditioning machines of heading 8415; parts thereof: Parts: Other: Other: Other: Other. We disagree,
as the Cold Storage Module is not an integral component of the water chilling process completed by the
Cooling Station. It does not contribute to the actual cooling process. The Cold Storage Module stores water
that was previously chilled and circulates this water during emergencies or power outages. Thus, the Cold
Storage Module is excluded from heading 8418.
By operation of Note 4 to Section XVI, HTSUS, the Cold Storage Module, imported in one shipment with all
its components, constitutes a functional unit in that its components contribute together to a clearly defined
function, which is thermal storage and discharge of chilled water.
Heading 8479, HTSUS, and Explanatory Note 84.79 provide for machines and mechanical appliances having
individual functions, not specified, or included elsewhere in Chapter 84, HTSUS. The Cold Storage Module
is not described by any other heading in Chapter 84, HTSUS. Accordingly, classification in heading 8479 is
appropriate.
Pursuant to GRI 1 (Section XVI Note 4), the applicable subheading for the Cold Storage Module will be
8479.89.9599, HTSUS, which provides for Machines and mechanical appliances having individual functions,
not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances:
Other: Other: Other. The general rate of duty is 2.5 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 8479.89.9599, HTSUS, listed above.
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, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 8479.89.9599, HTSUS, listed above.
Products of China classified under subheading 8479.89.9599, HTSUS, unless specifically excluded, are
subject to the additional 25 percent ad valorem rate of duty. At the time of importation, you must report the
Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8479.89.9599, 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 Arthur Purcell at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division