CLA-2-84:OT:RR:NC:N1:102
Sunday Ojajuni
Sunday Omogoriola Ojajuni DBA Elyon Customs Broker
93 W Rainbow Ridge Circle
Spring, TX 77381
RE: The tariff classification of a piping module from China
Dear Mr. Ojajuni:
In your letter dated November 3, 2025, on behalf of your client, DeepCoolAI Inc., you requested a tariff
classification ruling. Descriptive information was provided with your submission.
The piping module is a preengineered water circulating system that controls the flow of chilled water as it is
distributed to downstream connections such as a chiller, a thermal-storage tank and other terminal loads of a
HighEfficiency Maglev Integrated Cooling Station. The module is a framed system that incorporates pipes
equipped with flanges and approximately 29 steel valves configured as manually actuated butterfly valves,
electric valves and motorized modulating valves. The system also features three pressure sensors, four
pressure gauges, two thermometers and four flow meters that measure and report the operating conditions of
the module to the user. The operator uses this information to decide whether sections of valves need to
deliver water to bypass circuits, the flow rate controlled by the valves needs to be increased and to determine
if the valves need to be closed for emergency situations or to complete maintenance. The module will be
imported in a single shipment but unassembled due to its size.
In your letter, you suggest the module should be classified in accordance with Note 2b to Section XVI within
subheading 8418.99.8060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for
Refrigerators, freezers and other refrigerating or freezing equipment; parts thereof: Parts: Other: Other. We
disagree, as Note 2 to Section XVI states that subject to note 1 to this section, note 1 to chapter 84, and note 1
to chapter 85, parts of machines (not being parts of the articles of heading 8484, 8544, 8545, 8546 or 8547)
are to be classified according to the following rules:
(a) Parts which are goods included in any of the headings of chapter 84 or 85 (other than headings 8409,
8431, 8448, 8466, 8473, 8487, 8503, 8522, 8529, 8538 and 8548) are in all cases to be classified in their
respective headings;
(b) Other parts, if suitable for use solely or principally with a particular kind of machine, or with a number of
machines of the same heading (including a machine of heading 8479 or 8543) are to be classified with the
machines of that kind or in heading 8409, 8431, 8448, 8466, 8473, 8503, 8522, 8529 or 8538 as appropriate.
However, parts which are equally suitable for use principally with the goods of headings 8517 and 8525 to
8528 are to be classified in heading 8517, and parts which are suitable for use solely or principally with the
goods of heading 8524 are to be classified in heading 8529.
In this instance, the piping module is an assembly of valves, actuators and control devices designed to
regulate the flow of fluid to and from external systems, which is similar to the gas manifold assembly
described in Headquarters Ruling 963219, dated February 5, 2001. In this ruling, the gas manifold assembly
was determined to be a valve assembly classified within heading 8481 in accordance with Note 2(a) to
Section XVI. In recognizing the hierarchy nature of Note 2 to Section XVI, classifying the piping module
within heading 8418 in accordance with Note 2(b) to Section XVI is inapplicable.
The applicable subheading for the piping module will be 8481.80.9050, HTSUS, which provides for Taps,
cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including
pressure-reducing valves and thermostatically controlled valves; parts thereof: Other appliances: Other:
Other: Other. The general rate of duty will be 2 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 10 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 8481.80.9050, 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 will be su
bject 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 8481.80.9050
, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8481.80.9050, HTSUS, unless specifically excluded, are subject to an 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 8481.80.9050, 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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division