CLA-2-84:OT:RR:NC:N1:102
Ms. Nati Castaneda Danby Products Ltd.
1800 Production Drive
Findlay, Ohio 45840
RE: The tariff classification of a split air conditioner system and separate indoor and outdoor units from China
Dear Ms. Castaneda:
In your letter dated November 5, 2019 you requested a tariff classification ruling. Descriptive information was provided.
The product you intend to import is described as a split air conditioner system with a heat pump, model DAS120BAHWDB. The air conditioner system consists of an outdoor unit, part number DAS120BAHWDB-O, which is referred to as an condenser/compressor unit, and an indoor wall unit, part number DAS120BAHWDB-I, which is referred to as an evaporator. The system has dehumidification capabilities and has an output of less than 3.52 kW per hour. The system also features a reversing valve that allows for the system to change between cooling and heating cycles.
In your letter, you request a classification for the complete air conditioner system with heat pump and for the indoor and outoor units imported separately. In the scenario that concerns the importation of unassembled indoor and outdoor units that are used in the air conditioning system with a heat pump, it is said that the units will be imported separately.
As such, the applicable subheading for the indoor unit, part number DAS120BAHWDB-I, and the outdoor component of the split system, part number DAS120BAHWDB-O, imported separately, will be 8415.90.8065, 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: Other: Other: Of heat pumps. The general rate of duty is 1.4 percent ad valorem.
The applicable subheading for the split air conditioner system, model DAS120BAHWDB,
will be 8415.10.6000, HTSUS, which provides for split air conditioning machines, . . . : Other, except parts; incorporating a refrigerating unit and a valve for reversal of the cooling/heating cycle (reversible heat pumps); Other. The rate of duty will be 1 percent ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8415.10.6000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8415.10.6000, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8415.90.8065, HTSUS, unless specifically excluded, are subject to an additional 15 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 8415.90.8065, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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 the 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 Sandra Martinez at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division