CLA-2-84:OT:RR:NC:N1:102
BJ Shannon
Alston & Bird LLP
950 F Street NW
Washington, DC 20004
RE: The tariff classification of an icemaker from China
Dear Ms. Shannon:
In your letter dated December 9, 2025, you requested a tariff classification ruling on behalf of your client,
Pentair Commercial Ice, LLC.
The product under consideration is an icemaking machine, model number IYT0750W-261K. The stand-alone
machine systematically transforms water into ice through a continuous, automated process. The process
begins by drawing water from an external supply and directing it across an evaporator, in which water is
swiftly cooled to temperatures that allow for ice cubes to be formed. Once ice cubes are available, the
harvesting mechanism releases the cubes into an insulated storage bin. The machine is for commercial use
and consists of a rectangular shaped casing that houses an evaporator, a compressor, a condenser fan motor, a
water pump, valves, tubes, wires and other electrical components.
The applicable subheading for the icemaking machine will be 8418.69.0110, 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: Icemaking machines. The general rate
of duty will be Free.
In your letter, you explain that the evaporator incorporated into the icemaking machine is a product of the
United States and inquire whether the icemaking machine will be eligible for partial duty exemption under
subheading 9802.00.80, HTSUS, upon importation into the U.S. Subheading 9802.00.80, HTSUS, provides
for a partial exemption from duty on “articles assembled abroad in whole or in part of fabricated components,
the product of the United States, which (a) were exported in condition ready for assembly without further
fabrication, (b) have not lost their physical identity in such articles by change in form, shape, or otherwise,
and (c) have not been advanced in value or improved in condition abroad except by being assembled and
except by operations incidental to the assembly process, such as cleaning, lubricating, and painting.”
All the requirements of subheading 9802.00.80, HTSUS, must be satisfied before a component may receive a
duty allowance. An article entered under this tariff provision is subject to duty upon the full cost or value of
the imported assembled article, less the cost or value of the U.S. components assembled therein, upon
compliance with the documentary requirements of section 10.24, Customs Regulations (19 CFR § 10.24).
Section 10.14(a), Customs Regulations (19 CFR § 10.14(a)), states in part that the components must be in
condition ready for assembly without further fabrication at the time of their exportation from the United
States to qualify for the exemption. Components will not lose their entitlement to the exemption by being
subjected to operations incidental to the assembly either before, during, or after assembly with other
components.
Here, the evaporator incorporated into the icemaker machine is produced in the United States using
components that are sourced in the United States, which include coils of copper strip, copper sheets, copper
tubes, studs and soldering sheets and paste. The non-U.S. originating components, which account for a small
amount of the evaporator’s total cost, are the air nozzle, heat shrink tubes that facilitate the brazing process
and are removed prior to shipping, and plastic caps used to prevent contamination during shipping. In the
United States, the copper sheets are formed into a pan and grids (vertical and horizontal), the strips are cut,
and the tubes are cut and bent into specifically shaped tubes. Afterwards, the pan, grids, tubes, strips and air
nozzle are connected and welded in position to form an evaporator, which is subsequently coated using
electrolytic nickel sourced from the United Kingdom or the United States. The finished evaporator is then
exported to China ready to be assembled and connected with other components of an icemaker machine. It is
noted that while the evaporator is not subjected to further fabrication in China, a plastic frame that secures the
evaporator to the icemaking machine is affixed to the exterior of the evaporator.
Based on the aforementioned considerations, the evaporator is a U.S. fabricated component and is exported to
China in a condition ready for assembly without further fabrication. The installation of a frame in China does
not result in the evaporator losing its physical identity such that it changes its form, shape or otherwise. The
evaporator is not advanced in value or improved in condition. Therefore, as the evaporator has met the three
conditions outlined above, the imported icemaker machine qualifies for a partial duty exemption under
subheading 9802.00.80, HTSUS, provided that the documentary requirements of 19 CFR § 10.24 are met.
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 Sandra Martinez at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division