CLA-2-84:OT:RR:NC:N1:102
Larissa Andrade
Mobile Climate Control
7540 Jane Street
Vaughan L4K 0A6
Canada
RE: The tariff classification of an air conditioning system from Canada
Dear Ms. Andrade:
In your letter dated February 26, 2025, you requested a tariff classification ruling. Descriptive information
was provided with the submission.
The item in question is a Heating, Ventilation, and Air Conditioning (HVAC) system, item number
T13-21563-99. The HVAC system consists of various items that together regulate temperature and humidity
within the cabin of an all-terrain vehicle. The items, which are packaged together ready for retail sale, consist
of an evaporator, a condenser, a compressor, a heater, a control panel assembly, and three specifically
configured refrigerant hose assemblies that connect these components to each other.
The applicable subheading for the HVAC system, item number T13-21563-99 will be 8415.20.0000,
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 used for persons, in
motor vehicles. The general rate of duty will be 1.4 percent ad valorem.
You state that the country of origin of the HVAC system is Canada. Products of Canada as provided by
heading 9903.01.10 in Section XXII, Chapter 99, Subchapter III, U.S. Note 2(j), HTSUS, other than products
classifiable under headings 9903.01.11, 9903.01.12, 9903.01.13, 9903.01.14, and 9903.01.15, HTSUS, will
be subject to an additional 25 percent ad valorem rate of duty. At the time of entry, you must report the
applicable Chapter 99 heading, i.e. 9903.01.10, in addition to subheading 8415.20.0000, HTSUS, listed
above. Articles that are entered free of duty under the terms of general note 11 to the HTSUS
(U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set forth in subchapter XXIII of
Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be subject to the additional ad valorem
duties provided for in heading 9903.01.10. If your product is entered duty free as originating under the
USMCA, you must report heading 9903.01.14, HTSUS, in addition to subheading 8415.20.0000.
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/.
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 Sandra Martinez at sandra.martinez@cbp.dhs.gov.
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division