CLA-2-84:OT:RR:NC:N1:102
Mr. Martin J. Sveum
FedEx Trade Networks Transport & Brokerage
3813 – 4th Street NE
Great Falls, MT 59404
RE: The tariff classification, country of origin and marking of a water cooler and a reverse osmosis assembly from Canada
Dear Mr. Sveum:
In your letter dated January 27, 2010 you requested a tariff classification, country of origin and marking ruling on behalf of your client WaterGroup/Culligan.
The articles in question are a self-contained water cooler, unit number 4782, and reverse osmosis assembly, unit number 4784. The water cooler originates in China. The reverse osmosis assembly is “assembled” together in Canada from components originating in various countries, including Canada and the United States. You indicate that the water cooler may be imported separately or together with the reverse osmosis assembly.
The applicable subheading for the water cooler, when imported separately, will be 8418.69.0120, Harmonized Tariff Schedule of the United States (HTSUS), which provides for drinking water coolers, self-contained. The rate of duty is free.
The water cooler, when imported from Canada separately from the reverse osmosis assembly, must be marked to indicate China as its country of origin.
We need additional information in order to provide a ruling on the classification, country of origin and marking of the reverse osmosis assembly and the reverse osmosis/water cooler combination.
Please provide a detailed description of the assembly operations for the reverse osmosis assembly. Are the components that comprise the unit simply packaged together? Are any processes performed on the components after their importation into Canada? When the water cooler is combined with the reverse osmosis assembly are any assembly operations performed? In their condition as imported into the US, are the water cooler and reverse osmosis assembly packed together ready for retail sale and/or installation by dealers?
If you decide to resubmit your request, please include all of the material that we have returned to you and mail your request to U.S. Customs and Border Protection, Customs Information Exchange, 10th Floor, One Penn Plaza, New York, NY 10119, attn: Binding Rulings Section. If the information required does not involve sending a sample, you can re-submit your request and the additional information electronically.
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 on World Wide Web at http://www.usitc.gov/tata/hts/.
This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Kenneth T. Brock at (646) 733-3009.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division