CLA-2-84:OT:RR:NC:N1:103
Nathan Darling
Pekut and Carwick LLC
2390 4th Street, Suite D
Berkeley, CA 94710
RE: The tariff classification of a distilling system from Germany
Dear Mr. Darling:
In your letter dated January 2, 2026, you requested a tariff classification ruling.
The merchandise under consideration is referred to as a beverage spirit distilling system, model number
S-800, and is described as a commercial spirit still designed to produce alcoholic beverages. Its main
components include a copper distilling kettle (composed of a water bath casing, an agitator, and electrical
heating elements), a cylindrical copper helmet, a distilling column, a botanical basket, a condenser, and an
alcohol collector, all of which are interconnected by piping. The system has a 250-liter capacity and uses a
batch process to produce whiskey, gin, brandy, etc.
During its operation, a fermented wash is fed into the kettle where it is heated while the built-in agitator stirs
the wash to prevent scorching. As the wash is heated, the alcohol vapors rise and are collected in the copper
helmet, which is connected to the botanical basket. The botanical basket is only used when certain flavor
characteristics are desired in the final product. The vapors exit the botanical basket and continue to the
distilling column, which is designed for active reflux distillation. Three stages of bubble plates are located in
the distilling column which help increase the purity of the vapor. The purified vapors flow into the condenser
where they are condensed into a liquid and then collected in the collector.
In your submission, you suggest that the still is classifiable in heading 8419. We agree. Pursuant to note 4 to
Section XVI, the applicable subheading for the beverage spirit distilling system, model number S-800, will
be 8419.40.0040, 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: Distilling or rectifying
plant: For food and beverages.” The general rate of duty will be free.
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 Paul Huang at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division