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 [email protected].
Sincerely,
Steven A. Mack Director National Commodity Specialist Division