The tariff classification of a temperature control unit from South Korea

N361373May 28, 2026CLA-2-84:OT:RR:NC:N1:103
CATEGORY: Classification
TARIFF NO.: 8419.89.9585
Youngtae KimJangBaek Customs Attorney3F, 22, Bongeunsa-ro 37-gil, Gangnam-guSeoul 06108South KoreaRE: The tariff classification of a temperature control unit from South KoreaDear Mr. Kim:In your letter dated
May 8, 2026
, you requested a tariff classification ruling on behalf of your client, TechestCo., Ltd.The merchandise under consideration is referred to as an electric chiller, model number LC-80EC. Althoughcalled an “electric chiller,” the equipment is a single-channel temperature control unit used in semiconductorand display manufacturing. It is designed to heat or cool manufacturing equipment or target objects duringthe manufacturing process.The temperature control unit features a freestanding wheeled enclosure with multiple inlet and outlet ports.Its main components include a pump, a coolant reservoir, a valve, a remote controller, sensors, gauges, flowmeters, and a thermoelectric module assembly, which is an assembly composed of a thermoelectric modulepositioned between coolant blocks. During its operation, coolant stored in the reservoir is pumped to theprocess equipment where it absorbs heat, then returns to the unit and passes through coolant channels insidethe thermoelectric assembly. This assembly operates using the Peltier effect, which causes one side to absorbheat while the other side releases it. Cooling water supplied by the facility flows into the heat dissipation sideof the assembly and absorbs heat from the coolant. The coolant and cooling water do not mix during theprocess. The temperature control unit can also be used to heat the manufacturing equipment or target objectby reversing the polarity of the thermoelectric module.In your submission, you suggest that the temperature control unit is classifiable in heading 8419, HarmonizedTariff Schedule of the United States (HTSUS) and the remote controller is separately classified in heading8537, HTSUS. We agree in part. Both units will be imported packaged together in the same shipment andwill be used in a system that performs a clearly defined function described by heading 8419. As such, theywill be classified together as a functional unit.
The applicable subheading for the electric chiller, model number LC-80EC, will be 8419.89.9585, HTSUS,which provides for “Machinery, plant or laboratory equipment, whether or not electrically heated (excludingfurnaces, ovens and other equipment of heading 8514), for the treatment of materials by a process involving achange 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 kindused for domestic purposes; instantaneous or storage water heaters, nonelectric; parts thereof: Othermachinery, plant or equipment: Other: Other: Other: Other: For other materials.” The general rate of dutywill be 4.2 percent ad valorem.Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUSand the accompanying duty rates are provided at https://hts.usitc.gov/.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties as provided for in Subchapter III to Chapter 99, HTSUS.Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Paul Huang at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division