CLA-2-85:OT:RR:NC:N2:212
Sunday Ojajuni
Sunday Omogoriola Ojajuni DBA Elyon Customs Broker
93 W Rainbow Ridge Cir
Spring, TX 77381
RE: The tariff classification of a containerized control module from China
Dear Ms. Ojajuni:
In your letter dated November 24, 2025, you requested a tariff classification ruling on behalf of your client,
DeepCoolAI Inc.
The merchandise under consideration is described as a Control Module, which is specifically designed to be
used with the High-Efficiency Maglev Integrated Cooling Station, model DBCS-ACM-2100. The subject
control module is a containerized, skid-mounted electrical unit that incorporates various components. These
include electrical distribution cabinets, inverter cabinets, a programmable logic controller (PLC) with
corresponding control cabinets, Low Voltage/Extra-Low Voltage (LV/ELV) network cabinets, LED lighting,
degassing device, AC unit, and access controls. The subject unit is used as the primary power distribution and
control component for the cooling station.
In your request, you suggest that the correct classification for the control module should be 8537.10.9170,
Harmonized Tariff Schedule of the United States (HTSUS). As the various electrical components are
primarily used to distribute and control the greater unit, we agree.
The applicable subheading for the Control Module will be 8537.10.9170, HTSUS, which provides for
“Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or
8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other:
Other: Other.” The general rate of duty will be 2.7 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 8537.10.9170, 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 8537.10.9170, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8537.10.9170, 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 8537.10.9170, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at the following addresses:
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions
https://www.cbp.gov/trade/remedies/301-certain-products-china
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 Luke LePage at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division