CLA-2-84:OT:RR:NC:N1:105
Ashton Bennert
Air Oasis LLC
3401 Airway Blvd.
Amarillo, TX 79118
RE: The tariff classification of replacement air filters from China
Dear Mr. Bennert:
In your letter dated May 5, 2026, you requested a tariff classification ruling. Descriptive literature and a
sample was provided for our review.
The items under consideration are described as replacement air filters (model numbers AOIA-2SRF,
AOIA-2MRF, AOIA-2LRF, and AOIA-2PRF), which are dedicated replacements for the iAdaptAir 2.0
residential air purifiers. Each unit is a multi-stage composite filter consisting of H13 High-efficiency
polypropylene (PP) and polyester (PET) composite filter paper (>99.97% efficiency). The carbon phase has a
PP plastic honeycomb structure filled with ~70g (proportional to size) of modified columnar activated carbon
particles. The antimicrobial layer is a 35ppi silver-ion infused polyurethane filter cotton. Each filter has a
rigid PVC plastic frame with a polyester handle, PET non-woven banding, and sealed with PU foam (T3mm)
and hot-melt adhesive. The filters are imported in bulk case packs (4–10 units) for storage. Upon sale, they
are removed from the case packs and shipped as individual sets to the end-user.
Each of the filters are constructed the same way but are slightly different sizes. The AOIA-2SRF filter
measures 251mm long by 194mm wide by 40mm high. The AOIA-2MRF filter measures 519mm long by
194mm wide by 40mm high. The AOIA-2LRF filter measures 787.5mm long by 194mm wide by 40mm
high. The AOIA-2PRF filter measures 1057mm long by 194mm wide by 40mm high.
In your letter, you suggest the applicable subheading for the replacement air filters to be 8421.99.0180,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Centrifuges, including
centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Parts:
Other: Other.” We disagree. While the replacement air filters will be going into an air purifier, they are
considered a complete article by themselves with the ability to filter air. Therefore, they will not be
considered a part, and instead, be classified earlier in the heading.
Accordingly, the applicable subheading for the replacement air filters (model numbers AOIA-2SRF,
AOIA-2MRF, AOIA-2LRF, and AOIA-2PRF) will be 8421.39.0115, HTSUS, which provides for
“Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or
gases; parts thereof: Filtering or purifying machinery and apparatus for gases: Other: Dust collection and air
purification equipment: 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 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 Jason Christie at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division