CLA-2-84:OT:RR:NC:N1:102
Patrick Caulfield
GDLSK
599 Lexington Ave, FL 36
New York City, NY 10022
RE: The tariff classification of a dispenser head from China
Dear Mr. Caulfield:
In your letter dated October 23, 2025, on behalf of your client, iSi North America, you requested a tariff
classification ruling. Descriptive information was provided with your submission
The product under consideration is a dispenser head, item number 943011006. The dispenser head is
constructed of aluminum, zinc alloy, and plastic material, and is designed to be imported screwed onto a
refillable steel reservoir that has a capacity of 0.5 or 1.0 liters. The dispenser head when imported with a
reservoir is referred to as a whipped cream dispenser (item number CP 01 0060 00 CP), which is used in
coffee shops or similar environments. In use, cream is added to the reservoir, and the user depresses the lever,
which actuates the valve that controls the flow of nitrogen oxide gas from a container that is separately
imported. The process continues with a second valve permitting aerated cream to be released from the
dispensing tip.
Goods that are, prima facie, classifiable under two or more headings, are classifiable in accordance with
General Rule of Interpretation (GRI) 3, Harmonized Tariff Schedule of the United States (HTSUS). GRI 3(a)
states in part, when two or more headings each refer to part only of the materials or substances contained in
mixed or composite goods, those headings are to be regarded as equally specific, even if one heading gives a
more precise description of the good. Goods classifiable under GRI 3(b) are classified as if they consisted of
the material or component which gives them their essential character, which may be determined by the nature
of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in
relation to the use of the article. In instances when a complete whipped cream dispenser is imported, the
head, which is a valve assembly, imparts the essential character, when considering its value and its role
relative to the dispenser.
Accordingly, the applicable subheading for the dispenser head when imported with and without the reservoir
will be 8481.80.5090, 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: Hand operated: Of other materials: Other. The general rate of duty
will be 3 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 8481.80.5090, 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 8481.80.5090, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8481.80.5090, 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 8481.80.5090, 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