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NY F80645

January 5, 2000

CLA-2-84:RR:NC:1:104 F80645


TARIFF NO.: 8418.69.0090

Mr. Brandon Terrell
Fritz Companies, Inc.
1600 Genessee, Suite 450
Kansas City, MO 64102

RE: The tariff classification of a beverage cooling unit from China.

Dear Mr. Terrell:

In your letter dated December 2, 1999 on behalf of LA-Z-BOY Inc. of Monroe, Michigan you requested a tariff classification ruling.

The beverage cooling unit, sample submitted, will be installed in the arm of a LA-Z-BOY reclining chair. The cooler uses a thermoelectric module to keep pre-chilled beverages cool. (The operation is based on the Peltier Effect.) The unit runs off a DC power source, which is included with the unit. A silicon rubber “screw pad cover” is also included. The sample will be returned with the ruling.

The cooling cycle starts when the temperature inside the cooler is between 46 to 50 degrees F. or higher. The cooling cycle stops when the temperature has cooled to approximately 38 to 40 degrees F. While only pre-chilled food and beverage items should be used in the cooler, items that are warm can be chilled if the user doesn’t mind waiting several hours.

You have suggested that the appropriate classification of these coolers utilizing thermoelectric modules should be HTS subheading 8418.69.00 which provides for other refrigerating and freezing equipment. HQ ruling 957487 of September 5, 1995 classified a thermoelectric module imported by itself under 8418.69. Customs Cooperation Council Classification Opinion 8418.69/1 was cited.

The applicable subheading for the LA-Z-BOY beverage cooling unit will be 8418.69.0090, Harmonized Tariff Schedule of the United States (HTS), which provides for other refrigerating or freezing equipment: other. The rate of duty will be free.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Robert Losche at 212-637-7038.


Robert B. Swierupski

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