CLA-2-84:OT:RR:NC:N1:105
Stacy Han S & H Customs Broker, Inc. 13810 Cerritos Corporate Drive, Suite B Cerritos, CA 90703
RE: The tariff classification of water treatment systems from South Korea
Dear Ms. Han:
In your letter dated November 3, 2023, on behalf of your client, Navien America Inc., you requested a tariff classification ruling.
The items under consideration are described as advanced water treatment systems imported under model numbers WEC400 and WEC600. The WEC400 and WEC600 are similar in function and construct except for the two black modules inside the units. The WEC400 Navien Deionization (NDI) modules are smaller than the WEC600 NDI modules. The WEC600 also consumes slightly more power and can handle up to 500 parts per million total dissolved solids (TDS), while the WEC400 handles up to 300 parts per million. The WEC400 and WEC600 are both 22.4 inches wide by 16.9 inches deep by 31.4 inches high. Additionally, the WEC400 weighs 120 pounds and the WEC600 weighs 132 pounds.
The devices are whole-house water purification systems that use electro-deionization technology. The WEC water filters do not require salts to regenerate the system but instead use electromembrane technology to condition the water. Through this process, they reduce contaminants within the water including TDS and heavy metal such as iron and lead. They also function as salt-less water softeners with the ability to eliminate up to 80 percent of water hardness without salt.
The WEC400 and WEC600 are imported with the user manual, NaviLink Lite (enables Wi-Fi remote control compatibility), various tubing sizes, installation kit, L-Clip Elbow adapters, O-rings, retainer clips, pleated sediment filter cartridge, sediment filter housing (plumbed into the feed line before the WEC unit), filter housing wrench, mounting bracket, screws, and NPT straight adapters.
The applicable subheading for the WEC400 and WEC600 advanced water treatment systems will be 8421.21.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for liquids: For filtering or purifying water.” The general rate of duty will be 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 at https://hts.usitc.gov/current.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
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 Jason Christie at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division