CLA-2-85:OT:RR:NC:N4:110
Mr. Paul S. Anderson
The Anderson Law Firm, LLC
125 South Wacker Drive, Suite 1825
Chicago, IL 60606
RE: The tariff classification of convection assemblies from China
Dear Mr. Anderson:
In your letter dated July 29, 2016, on behalf of your client International Buying Group, Ltd. (IBG), you requested a tariff classification ruling.
The merchandise under consideration is referred to as the “convection assemblies”, exclusively designed for use in household type convection ovens and ranges.
You have stated that the convection assemblies will be manufactured and sold in two different versions, which differ slightly in component make-up but are nearly identical in function. The first type is identified as the “true convect” version or “true convection assemblies”, part numbers W10874067, W10874472 and W10874477. The second type is referred to as the “fan convection assembly”, part number W10617485.
The “true convection assemblies” and the “fan convection assembly” include, at the time of importation, a convection plate, convection element, an insulation plate, a motor convection fan, an insulation/convection pad made of fiberglass and a cooling fan. However, unlike the “fan convection assembly” version, the “true convection assemblies” version contain a heater element at the time of importation that will be assembled to the unit after importation.
The convection fan or motor/fan assembly portion of the convection assembly consists of a 120V motor, a fan blade, a shaft, a mounting bracket and a small fan to keep the motor cool. The motor/fan assembly distributes heated air throughout the convection oven. The insulation plate, the convection plate and the insulation pad are attached to the motor/fan assembly. The insulation plate secures the insulation pad and blocks oven heat from going back to the motor. The purpose of the convection plate is to reflect oven heat back into the oven cavity and to provide a surface for mounting the motor/fan assembly. The purpose of the motor fan is to distribute/circular the heated air in the oven.
The applicable subheading for the convection assembly will be 8516.90.8050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other parts for the cooking stoves, ranges and ovens of subheading 8516.60.40, HTSUS. The rate of duty is 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 on World Wide Web at https://hts.usitc.gov/current.
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 Hope Abada at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division