CLA-2-84:OT:RR:NC:N1:103
Robert Menendez
Seko Customs Brokerage Inc.
6302 N Anderson Rd.
Tampa, FL 33634
RE: The tariff classification of aluminum welded channel coolers from China
Dear Mr. Menendez:
In your letter dated March 18, 2022, you requested a tariff classification ruling on behalf of your client, JTL Enterprises, Inc. DBA HydroMassage.
The part under consideration is referred to as an “aluminum welded channel cooler” used in beds and loungers. The cooler is imported under part numbers BIG-0800, BIG-0801, and BIG-0804. While the part numbers differ in dimensions, the design of each cooler is the same. Each unit consists of two electric fans mounted on a brazed aluminum plate-fin heat exchanger. The function of the cooler is to remove heat that is generated by the internal water pressure during a massage. The unit is connected to a circulating water supply within a chair, bed, or lounger. Heated water enters from an inlet at the top of the heat exchanger and traverses the unit before exiting through a second outlet. As the heated water travels through the unit, the fans blow air over the heat exchanger, transferring heat from the water to ambient air.
The applicable subheading for the aluminum welded channel coolers, part numbers BIG-0800, BIG-0801, and BIG-0804, will be 8419.50.1000, Harmonized Tariff Schedule of the United States (“HTSUS”), which provides for “Machinery, plant or laboratory equipment, whether or not electrically heated (excluding furnaces, ovens and other equipment of heading 8514), for the treatment of materials by a process involving a change of temperature such as heating, cooking, roasting, distilling, rectifying, sterilizing, pasteurizing, steaming, drying, evaporating, vaporizing, condensing or cooling, other than machinery or plant of a kind used for domestic purposes; instantaneous or storage water heaters, nonelectric; parts thereof: Heat exchange units: Brazed aluminum plate-fin heat exchangers.” The rate of duty will be 4.2 percent ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8419.50.1000, 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., 9903.88.01, in addition to subheading 8419.50.1000, 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, including information on exclusions and their effective dates, 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 Paul Huang at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division