CLA-2-84:OT:RR:NC:N1:104
Anthony Sinclair
BeerMe LLC
8 The Green,
Dover, DE 19901
RE: The tariff classification of can tossing cooler from China
Dear Mr. Sinclair:
In your letter dated March 26, 2026, you requested a tariff classification ruling.
The product in question is a motorized, spring-loaded beverage can tossing or launching device housed
within a rotomolded polyethylene insulated cooler shell. The launching device is comprised of a DC geared
motor, cam, springs, limit switches, control PCB, sheet-metal guides and magazine structure, launch cradle,
trigger mechanism, and lid aperture/flap that work together in a defined sequence to load, cock, eject, and
automatically reload one standard 12 oz can on command. The can tossing cooler ejects the beverage cans
upwards about four feet through the lid flap. The user activates the toss mechanism by lightly kicking a panel
positioned on the side of the cooler. The unit is imported fully assembled with reusable gel ice packs but
without a battery required for the tossing device. The product does not incorporate an active refrigerating
element.
Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is
determined through the application of the General Rules of Interpretation (GRIs), taken in order. GRI 1
provides that classification shall be determined according to the terms of the headings and any relative
section or chapter notes. Since no one tariff heading covers the components of the product as a whole, GRI 1
is inapplicable. As the can tossing cooler is comprised of a cooler shell and launcher mechanism that are
classified in different headings, and the components are adapted to each other, we consider it to be a
composite good despite the fact that the tossing device is removeable from the cooler shell and can be used as
a stand-alone unit. See Explanatory Notes Rule 3(b)(IX) (“composite goods made up of different components
shall be taken to mean not only those in which the components are attached to each other to form a
practically inseparable whole but also those with separable components, provided these components are
adapted one to the other and are mutually complementary and that together they form a whole which would
not normally be offered for sale in separate parts”).
Composite goods are classified in accordance with GRI 3(b), which provides that such goods are to be
classified according to the component that gives the goods their essential character. Explanatory Note (EN)
VIII to GRI 3(b) explains that “the factor which determines essential character will vary as between different
kinds of goods. It may, for example be determined by the nature of the material or component, its bulk,
quantity, weight or the use of the goods.” When the essential character of a composite good can be
determined, the whole product is classified as if it consisted only of the material or component that imparts
the essential character to the composite good. In your submission, you state that the mechanical launching
assembly accounts for approximately 57 percent of the total manufacturing cost. The insulated cooler shell,
including the body, lid, handles, and feet, accounts for approximately 43 percent of the cost. The cooler body
is specifically designed to accommodate the dispensing mechanism, featuring a structural cut-out for the
launching system and a lid configured with an opening for can ejection. Additionally, the product’s can
tossing function features prominently in the company’s marketing. In this office’s opinion, the motorized,
spring-loaded beverage can tossing device imparts the essential character to the can tossing cooler.
The applicable subheading for the can tossing cooler will be 8479.89.9599, HTSUS, which provides for
“Machines and mechanical appliances having individual functions, not specified or included elsewhere in this
chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other.” The general rate of
duty will be 2.5 percent ad valorem.
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 the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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)
James P. Forkan
Director
National Commodity Specialist Division