RE: The tariff classification of an industrial water cooling tower from South Korea

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364501 September 2, 2026 CLA-2-84:OT:RR:NC:N1:103 CATEGORY: Classification TARIFF NO.: 8419.89.9540 Hyunwook Cho Daewon Customs Service Company 43-14, Gasan digital 2-ro, Geumcheon-gu Seoul 08588 South Korea RE: The tariff classification of an industrial water cooling tower from South Korea Dear Mr. Cho: In your letter dated August 23, 2026, you requested a tariff classification ruling on behalf of your client, Seongdo USA Inc. The merchandise under consideration is an industrial steel water cooling tower, model number OTTX-250L, with an induced-draft, cross-flow, and open-circuit design. It features a cold-water basin, a hot-water basin, and dual vertical fill banks mounted in a structural frame enclosed by panels. During its operation, hot process water is piped to the top of the unit, where it is distributed by gravity over PVC packing in the fill banks, which are located on opposite sides of the unit. At the top of the unit is an induced-draft fan assembly equipped with an axial air-foil fan. The fan draws ambient air into the unit, where it flows perpendicular to the falling water and then passes through drift eliminators before exiting the tower. As the water and air make direct contact, heat is transferred through evaporation. The cooled water collects in the cold-water basin at the base and returns to the process equipment. This unit has a cooling capacity of 975,000 kcal per hour and measures approximately 2.4 meters in length, 4.4 meters in width, and 3.19 meters in height. In your submission, you suggest that the subject cooling tower is classifiable in heading 8419, Harmonized Tariff Schedule of the United States (HTSUS). We agree. The applicable subheading for the industrial water cooling tower, model number OTTX-250L, will be 8419.89.9540, HTSUS, which provides for “Machinery, plant or laboratory equipment, whether or not electrically heated (excluding furnaces, ovens and other equipment of heading 8514), for the treatment of materials by a process involving a change 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 kind used for domestic purposes; instantaneous or storage water heaters, nonelectric; parts thereof: Other machinery, plant or equipment: Other: Other: Other: Other: Designed for cooling: Other.” The general rate of duty will be 4.2 percent ad valorem. 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties 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 either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems 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 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 Paul Huang at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division