CLA-2-84:OT:RR:NC:RR:N1:118
Stephen Cox
The Curators of the University of Missouri on behalf of the University of Missouri
3600 New Haven Rd.
Columbia, MO 65201
RE: The tariff classification of a cattle feeding and watering system from Denmark
Dear Mr. Cox:
In your letter dated January 28, 2026, you requested a tariff classification ruling.
The merchandise under consideration is identified as the RIC2Discover System, which is designed to provide
feed and water to cattle. It also records the feed and water intake per animal using RFID identification and
integrated weighing technology. You have stated that the system will be used on research farms, universities,
and dairy and beef farms that work with feed companies, genetic companies or pharmaceuticals companies.
The complete system will be imported with the following components:
18 stainless steel feed-weigh troughs with RFID gates.
2 water-weigh troughs.
Control system that includes management software, process controllers, interface cables, and zone
units.
Mounting poles, brackets, and an installation kit.
You suggested classifying the system within subheading 8434.90.0000, Harmonized Tariff Schedule of the
United States (HTSUS), as parts of milking machines and dairy machinery. We disagree. The RIC2Discover
System does not extract milk from cattle or process dairy and is not a part of such machinery. Therefore,
your proposed classification is inapplicable.
Note 4 to Section XVI of the HTSUS describes a functional unit as a machine or combination of machines
consisting of individual components (whether separate or interconnected by piping, transmission devices,
electric cables or by other devices) intended to contribute together to a clearly defined function covered by
one or more of the headings in chapter 84 or chapter 85. The whole then falls to be classified in the heading
appropriate to that function. The RIC2Discover System meets this description, with the clearly defined
function of feeding and watering cattle.
The applicable subheading for the RIC2Discover System will be 8436.80.0090, HTSUS, which provides for
“Other agricultural, horticultural, forestry, poultry-keeping or bee-keeping machinery, including germination
plant fitted with mechanical or thermal equipment; poultry incubators and brooders; parts thereof: Other
machinery…. Other: Other: Other.” 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 Anthony Grossi at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division