CLA-2-84:OT:RR:NC:N1:102
Marcos Pordeus de Paula
Eq Tech Equipamentos Ltda
Rod BR 280, n. 13700
Guaramirim, 89270-000
Brazil
RE: The tariff classification of refrigeration equipment from Brazil
Dear Mr. Pordeus de Paula:
In your letter dated November 18, 2025, you requested a tariff classification ruling. Descriptive information
was provided with your submission.
The products at issue are referred to as Flex Line refrigeration equipment. The self-contained equipment
consists of a reinforced housing with an integrated piston type of compressor, a condenser, an evaporator, an
expansion device and an electronic control module. The closed-circuit systems circulate R134a or R404A
refrigerant to maintain controlled temperatures ranging between approximately 0 to 50 degrees Fahrenheit
within insulated enclosures that store and transport temperature-sensitive goods. Defrost is automatic and
controlled by temperature and time sensors.
The applicable subheading for the Flex Line refrigeration equipment will be 8418.69.0150, 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: Other refrigerating or freezing equipment; heat pumps: Other: Reciprocating
liquid chilling refrigerating units. The general rate of duty will be Free.
Effective August 6, 2025, Executive Order 14323 imposed additional duties on products from Brazil. At this
time, products of Brazil provided by heading 9903.01.77, except for products described in headings
9903.01.78 – 9903.01.83 and, will be subject to an additional ad valorem rate of duty of 40 percent. At the
time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e.,
9903.01.77, in addition to subheading 8418.69.0150, 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 Brazil 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., 9903.02.09, in addition to subheading
8418.69.0150, 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