CLA-2-84:OT:RR:NC:N1:102
Ron Levy
Kintetsu World Express USA Inc
18450 S. Wilmington Avenue
Rancho Dominguez, CA 90220
RE: The tariff classification of air conditioning fittings from Japan
Dear Mr. Levy:
In your letter dated May 5, 2026, you requested a tariff classification ruling, on behalf of your client,
Nichirin-Flex USA Inc.
Part numbers E10294, E10295, J39037, and J38938 are referred to as air conditioning fittings. The fittings
consist of pipes that are bent to shape to fit within a designated space in a motor vehicle and fittings that
interface with the components of an air conditioning system. The aluminum fittings facilitate refrigerant flow
between the condenser, compressor, and evaporator.
In your letter, you suggest the air conditioning fittings are classified within subheading 7609.00.0000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for Aluminum tube or pipe
fittings (for example, couplings, elbows, sleeves). We disagree. Based on the information provided, the
products in question are pipes with fittings attached. As the pipes are bent to a specific configuration, making
them a specific identifiable article, they are precluded from classification in heading 7608 as pipes. Because
the fittings that are attached to the pipes connect to hoses made of many materials, they are also precluded
from being classified as pipe fittings in heading 7609 as the fittings are intended to be exclusively used
within an air conditioning system. Furthermore, CBP has previously classified similarly configured air
conditioning hoses as parts of air conditioning systems within heading 8415. See Headquarters Ruling Letter
956700, dated October 24, 1994.
The applicable subheading for the air conditioning fittings will be 8415.90.8045, HTSUS, which provides for
Air conditioning machines, comprising a motor-driven fan and elements for changing the temperature and
humidity, including those machines in which the humidity cannot be separately regulated; parts thereof:
Parts: Other: Other: Of automotive air conditioners. The general rate of duty will be 1.4 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 Sandra Martinez at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division