CLA-2-84:OT:RR:NC:N1:103
Lance Dornn
Ram’d Air Gear Dryer Ltd.
44 Limestone Road East
Brandon, MB R7A 7L5
Canada
RE: The tariff classification of a heat air dryer from Canada
Dear Mr. Dornn:
In your letter dated November 20, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as the Ram Air Gear Dryer and is described as a system
that uses heat to dry firefighting gear. It has a rectangular pipe frame made up of two vertical posts and a
horizontal pipe that runs across its top. The frame (also referred to as an air chamber in your submission)
functions as a conduit for transporting heated air. The top air chamber has downward-facing ports that are
connected to “stickmen,” which are pipe frames for firefighting equipment. The air chambers are connected
to a power pack, which is described as a cabinet that contains a fan assembly and a touchscreen control panel.
A heating element is mounted in the air chamber directly after the power pack.
There are drying ports throughout the entire frame. The ports are fitted with adapters and holders for specific
types of personal protective equipment (e.g., hazmat suits, helmets, gloves, boots, and other structural
firefighting gear). The power pack forces heated air through the air chambers, out the adapters, and onto the
equipment.
The Ram Air Gear Dryer will be imported under model numbers TG-4H, TG-6H, and TG-8H. They all
operate the same way but have a different number of stickmen (ranging from four to eight) and ports (ranging
from twelve to twenty-four). The overall dimensions of the smallest model are approximately 80 inches in
length, 28 inches in width, and 97.5 inches in height.
We note that the Ram Air Gear Dryer is also available in a “non-heated” version. This ruling only concerns
the heated version.
The applicable subheading for the Ram Air Gear Dryer will be 8419.39.2080, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for “Machinery, plant or laboratory equipment, whether or not
electrically heated (excluding furnaces, ovens and other equipment of heading 8514), for the treatment of
materials by a process involving a change of temperature such as heating, cooking, roasting, distilling,
rectifying, sterilizing, pasteurizing, steaming, drying, evaporating, vaporizing, condensing or cooling, other
than machinery or plant of a kind used for domestic purposes; instantaneous or storage water heaters,
nonelectric; parts thereof: Dryers: Other: Other.” The general rate of duty will be free.
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. At
the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.10, in addition to
subheading 8419.39.2080, 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 8419.39.2080, 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 8419.39.2080, 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 Paul Huang at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division