CLA-2-84:OT:RR:NC:N1:102
Justin Han
S & H Customs Broker Inc.
13810 Cerritos Corporate Drive, Suite B Cerritos, CA 90703
RE: The tariff classification of Heat Pump and Air Handler units from China
Dear Mr. Han:
In your letter dated April 20, 2023, you requested a tariff classification ruling on behalf of your client, Navien Inc. DBA Navien America. Descriptive information was provided with your submission inclusive of a Technical Manual.
The products in question are the Vertical Discharge Outdoor Unit, referred to as a Heat Pump, and the Indoor Unit, which is referred to as the Air Handler Unit. Both, the heat pump and the air handler unit will be imported and distributed together, as the 16SEER2 Series split air conditioning system.
The Heat Pump is comprised of a compressor, heat exchanger, expansion valve, and 4-way valve intended for both cooling and heating air. There are four models of the outdoor units: COT-24CNVR1-18, COT-36CNVR1-18, COT-48CNVR1-18, and COT-60CNVR1-18.
The Air handler unit is promised of a heat exchanger, expansion valve, a blower with a drain connection. The Air Handler unit is designed to dispense temperature-controlled air. There are four models of the indoor units: CAHi-24CNVR1-18, CAHi-36CNVR1-18, CAHi-48CNVR1-18, and CAHi-60CNVR1-18.
The applicable subheading of the Heat Pump and Air Handler unit, when imported and distributed together as the 16SEER2 Series split air conditioning system, will be 8415.10.6000, Harmonized Tariff Schedule of the United States (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: Of a kind designed to be fixed to a window, wall, ceiling, or floor, self-contained or “split-system”: Other: Incorporating a refrigerating unit and a valve for reversal of the cooling/heat cycle (reversible heat pumps). The general rate of duty is 1 percent ad valorem.
The applicable subheading for the Heat Pump, model numbers COT-24CNVR1-18, COT-36CNVR1-18, COT-48CNVR1-18, and COT-60CNVR1-18, when 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 thereof: Parts: Other: Other: Of heat pumps. The general rate of duty is 1.4 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. The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading.
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 7.5 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 tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading.
More information is needed to determine the classification of the Air Handler unit, as it is unclear whether this product can be used with other types of outdoor units or exclusively with the subject heat pumps. 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 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,
Steven A. Mack
Director
National Commodity Specialist Division