CLA-2-84:OT:RR:NC:N1:104
Nicolas Ramirez
Paradigm Evergreen Inc
2645 S Bayshore Dr, Unit 1203
Miami, FL 33133
RE: The tariff classification of a top loading washer dryer machine from China
Dear Mr. Ramirez:
In your letter dated December 1, 2025, you requested a tariff classification and marking ruling.
The merchandise under consideration is a compact, top loading combination household washer and dryer
unit, model eeva01. This electrically powered machine is comprised of a stainless-steel washing drum and
tub, a main cabinet body, a drive train (consisting of a brushless DC motor, a belt drive, flat wrap spring
clutch), washing impeller, evaporation dryer system, water valves and a recirculation pump, and a bottom
drawer compartment with two slide-out water tanks. One tank provides a source of clean water and and the
other captures dirty wash water. The machine measures approximately 19" W x 20" D x 40" H, and is
designed for residential use. The eeva01 is capable of performing six automatic wash/dry programs, activated
via a touch-screen control panel on the machine’s lid. The machine has a wash-to-dry linen capacity of 2.5 kg
and a wash-through-dry capacity of 2.5 kg.
The eeva01’s water tanks allow it to operate without a plumbing connection. Before each wash the user
places the two tanks into the bottom drawer and closes it to connect them to the unit, allowing water to be
pumped into the system. After the wash, the user opens the drawer to dispose of the dirty wash water.
Alternatively, the unit can be connected to a water tap, which would require the user to manually connect and
disconnect the fitting before and after each use. A drain hose can also be used in lieu of the dirty wash water
tank. In either case, the machine’s programmed wash-and-dry cycles are fully automatic.
CLASSIFICATION
In your submission, your suggest that the eeva01 is classifiable in subheading 8450.12.00, Harmonized Tariff
Schedule of the United States (HTSUS), which covers “Household- or laundry-type washing machines, not
fully automatic, with a built-in centrifugal dryer, with a dry linen capacity not exceeding 10 kg.” You claim
that the machine is not “fully automatic” within the meaning of subheading 8450.11, HTSUS, because the
user must fill and empty the water tanks before/after each wash cycle, or attach a hose for these purposes. We
disagree.
The Harmonized Commodity Description and Coding System Explanatory Notes (EN), constitute the official
interpretation at the international level. While neither legally binding nor dispositive, the ENs provide a
commentary on the scope of each heading of the HTSUS and are generally indicative of the proper
interpretation of the headings. It is Customs and Border Protection (CBP) practice to follow, whenever
possible, the terms of the ENs when interpreting the HTSUS. See T.D. 89-80, 54 Fed. Reg. 35127, 35128
(August 23, 1989). The ENs to heading 8450 provide in pertinent part:
The heading covers household or laundry-type washing machines (whether or not electric and
whatever the weight), which are normally used in the household, commercial laundries, hospitals,
etc., to clean linens, finished goods, etc. They usually have paddles or rotating cylinders for keeping
the liquid circulating through the contents, or sometimes a device to give high frequency vibrations to
the liquid.
The heading also covers machines which both wash and dry.
***
Subheading 8450.11
This subheading covers washing machines which, once the programme has been selected, wash, rinse
and spin without the intervention of the user.
The eeva01 employs programmed controls to automatically wash, spin, and dry (if dry mode is selected).
Laundry is washed and dried in the same drum of the unit. While the user must add water (manually via the
tank or by connecting a separate water line) before each load and empty the dirty water tank after each
wash/dry cycle (or by attaching a drain hose), once the user selects a wash/dry cycle program, the machine
autonomously washes, spins, and dries the laundry without further action by the user.
The applicable subheading for the eeva01 washer dryer machine will be 8450.11.0040, HTSUS, which
provides for “Household- or laundry-type washing machines, including machines which both wash and dry. .
.: Machines, each of a dry linen capacity not exceeding 10 kg; Fully automatic machines: Other: Top
Loading.” The general rate of duty will be 1.4 percent ad valorem.
MARKING
You also requested a ruling on the proper country of origin marking of the machine and its container. You
provided a mock-up of a combined country of origin and product information label. The words “Made in
China” will appear on the label together with the product’s model and serial number, electrical specifications,
UL certification, and the words “For Indoor Use Only.” This label will appear inside and at the rear of the
tank drawer compartment, behind the two tanks. The product’s outermost carton will have the same or
similar country of origin/product information label, which will be printed near the bottom of one side of
outermost carton.
The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless
excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a
conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will
permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country
of origin of the article.
As provided in section 134.41(b), Customs Regulations (19 CFR 134.41(b)), the country of origin marking is
considered conspicuous if the ultimate purchaser in the U.S. is able to find the marking easily and read it
without strain.
With regard to the permanency of a marking, section 134.41(a), Customs Regulations (19 CFR 134.41(a)),
provides that as a general rule marking requirements are best met by marking worked into the article at the
time of manufacture. For example, it is suggested that the country of origin on metal articles be die sunk,
molded in, or etched. However, section 134.44, Customs Regulations (19 CFR 134.44), generally provides
that any marking that is sufficiently permanent so that it will remain on the article until it reaches the ultimate
purchaser unless deliberately removed is acceptable.
While the proposed marking of imported article appears to be sufficiently permanent and legible, is not in a
conspicuous place. Rather, the position of the origin label, at the back of the inside drawer compartment,
would require the user to bend down and remove the two drawers in order to locate and read it. Therefore, the
proposed marking of the eeva01 does not satisfy the marking requirements of 19 U.S.C. 1304 and 19 CFR
Part 134 and is therefore not an acceptable country of origin marking for the imported product.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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 Arthur Purcell at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division