CLA-2-84:OT:RR:NC:N1:103
Maureen Celmer
Welke Customs Brokers USA, Inc.
36 Delaware St.
Tonawanda, NY 14032
RE: The tariff classification of pellet production equipment from Canada
Dear Ms. Celmer:
In your letter dated April 14, 2026, you requested a tariff classification ruling on behalf of your client, Camar
Mill Systems Ltd.
The first item under consideration is described as the Camar HD Micro Ingredient System, which is a
specialized equipment set installed in feed mills for the precise measurement of small-quantity ingredients
used in animal feed. This system includes bins for product storage, a product metering system, a traveling
scale, and an accompanying control panel. The HD Micro digital scale, supported by load cells and featuring
a digital display, has a maximum capacity of 15 pounds and a minimum capacity of 0.002 pounds.
Functioning as one of the batching scales within the system, it connects via a pneumatic conveyor to
discharge measured ingredients into the mixer. Here, these ingredients are combined with those from other
scales in the system. The thoroughly mixed product then proceeds through the process, either to pelleting or
directly to loadout bins. The ingredients typically weighed by the Micro system are in very small amounts
and commonly include flavor and performance additives or medications for animal health. The HD Micro
dispenses product through a three-stage fine feeder into a small-scale hopper. This hopper travels to each
required bin for weighing. Once weighing is complete, the scale hopper moves to the discharge position,
inverts, and empties its contents through a gate at the bottom into the pneumatic conveyor for transport to the
mixer.
The second item under consideration is described as the Camar SD Micro Ingredient System, which is a
specialized equipment set designed for feed mills to accurately measure small quantities of ingredients for
animal feed. This system includes product bins, a product metering system, weigh hoppers, and a control
panel. The SD Micro digital scale, supported by load cells and featuring a digital display, has a maximum
capacity of 220 pounds and a minimum capacity of 0.05 pounds. It functions as one of the batching scales
within the system, discharging measured ingredients via a pneumatic conveyor into the mixer. Here, these
ingredients are combined with those from other scales in the system. The mixed product then proceeds
through the process, either to pelleting or directly to loadout bins. Similar to the first item, the ingredients
typically weighed by the SD Micro system are in very small amounts and commonly include flavor and
performance additives or medications for animal health. The SD Micro dispenses product into a fixed scale
hopper, with each bin equipped with a small screw feeder. Ingredients for a batch are weighed individually.
The scale hopper discharges into another hopper that then conveys the product pneumatically to the mixer.
The third item under consideration is referred to as the Camar Counterflow Cooler and is described as a
machine used to cool pellets and other granular products. The cooler is typically placed below the pellet mill
and has a tower-like structure that tapers into a V-shaped hopper at the bottom. During its operation, newly
formed pellets are fed into the top of the tower and flow through multiple cooling decks. The pellets are
cooled by air that flows upwards through the product. A bypass air damper system regulates the airflow and
cooling rate, allowing the pellets to be cooled within 18 degrees Fahrenheit of the cooling air temperature.
The fourth item is the Camar Pellet Crumbler, model 16x84. This machine is installed in a feed mill below
and attached to the Camar Counterflow Cooler to reduce the size of pellets so they can be consumed by
smaller or younger animals. The flow rate of the pellets is regulated by an inlet feed roller. The pellets pass
through corrugated crumbler rolls which cut and crush the pellets into smaller, uniform-sized particles. Pellet
particle size is controlled by adjusting the gap between the crumbler rolls; for pellets produced for larger
animals, the roll gap is opened wide to allow the whole pellets to pass through without being crumbled. The
corrugated rolls are driven at different speeds by an electric motor and belt drive. Pellet screening is
performed by an external machine and is not part of the pellet crumbler.
The fifth item is the Camar Pellet Mill Conditioner, model 24x120. This mixing machine resembles a large
cylinder and is installed in an animal feed mill in tandem with a pellet mill to prepare animal feed mash. In
operation, a screw feeder controls the feed rate of the mash into the conditioner. Live steam is injected into
the product through multiple steam nozzles. The steam is mixed with the product by the rotating conditioner
shafter and paddles to maximize the adsorption of the steam into the product. Paddle configuration controls
the mash retention time in the conditioner. The conditioner does not include any burners or heating elements.
Conditioned mash exits the conditioner with added heat and moisture as required for pelleting and is
discharged into the pellet mill.
You suggested classifying each machine within subheading 8438.80.0000, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for machinery, not specified or included elsewhere in this
chapter, for the industrial preparation or manufacture of food or drink. We disagree. Merchandise is classified
in its condition as imported at the time of entry. Classification of merchandise under the HTSUS is governed
by the General Rules of Interpretation (GRIs) taken in order. GRI 1 provides that classification is determined
first in accordance with the terms of the headings and any relative section and chapter notes. Your ruling
submission stated that the machines will be imported in multiple shipments over an unspecified period of
time. As such, each machine will be classified in their respective headings at the time of importation in
accordance with GRI 1.
The applicable subheading for the Camar HD Micro Ingredient System will be 8423.81.0040, HTSUS, which
provides for “[w]eighing machinery (excluding balances of a sensitivity of 5 cg or better), including
weight-operated counting or checking machines; weighing machine weights of all kinds; parts of weighing
machinery: Other weighing machinery: Having a maximum weighing capacity not exceeding 30 kg: Digital
electronic type: Other.” The general rate of duty will be free.
The applicable subheading for the Camar SD Micro Ingredient System will be 8423.82.0010, HTSUS, which
provides for “[w]eighing machinery (excluding balances of a sensitivity of 5 cg or better), including
weight-operated counting or checking machines; weighing machine weights of all kinds; parts of weighing
machinery: Other weighing machinery: Having a maximum weighing capacity exceeding 30 kg but not
exceeding 5,000 kg: Digital electronic type.” The general rate of duty will be free.
The applicable subheading for the Camar Counterflow Cooler will be 8419.89.9540, HTSUS, which provides
for “[m]achinery, 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: Other machinery, plant
or equipment: Other: Other: Other: Designed for cooling: Other.” The general rate of duty will be 4.2 percent
ad valorem.
The applicable subheading for the Camar Pellet Crumbler will be 8479.82.0080, HTSUS, which provides for
“[m]achines and mechanical appliances having individual functions, not specified or included elsewhere in
this chapter; parts thereof: Other machines and mechanical appliances: Mixing, kneading, crushing, grinding,
screening, sifting, homogenizing, emulsifying or stirring machines: Other.” The general rate of duty will be
free.
The applicable subheading for the Pellet Conditioner will be 8479.82.0080, HTSUS, which provides for
“[m]achines and mechanical appliances having individual functions, not specified or included elsewhere in
this chapter; parts thereof: Other machines and mechanical appliances: Mixing, kneading, crushing, grinding,
screening, sifting, homogenizing, emulsifying or stirring machines: Other.” The general rate of duty will be
free.
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 Paul Huang at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division