The tariff classification of a cordless robotic pool cleaner from China

N352394 August 22, 2025 CLA-2-84:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 8421.21.0000; 9903.01.24; 9903.01.25; 9903.88.01 Lee Li Mammotion Technology LLC 13640 Redwood Court Chino, CA 91710 RE: The tariff classification of a cordless robotic pool cleaner from China Dear Mr. Li: In your letter dated August 14, 2025, you requested a tariff classification ruling. The item under consideration is the SPINO E1, which is a cordless robotic pool cleaner designed to automatically remove debris and dirt from swimming pools. The device features a built-in, removable, and reusable filter basket. The filter mesh has a pore size of 180 microns and is capable of capturing common solid debris such as leaves, dust, and sand. The system filters up to 96 gallons of water per minute. The filtration process is supported by three motors: one drives the water intake for filtration, while the other two enable movement along the pool floor to ensure broad surface coverage. During operation, a rotating brush helps guide debris toward the suction inlet, where it is collected into the filter basket and clean water is discharged back into the pool. The device is activated with a single button and follows a fixed movement path. It includes basic directional adjustment when encountering obstacles to avoid damage during cleaning. When fully charged, the battery supports up to 180 minutes of operation, covering around 1,600 square feet. Once the battery is low, the device moves to the poolside waterline for 15 minutes for easy manual retrieval. A quick-drain design allows for fast and efficient cleaning of the filter basket. The unit measures 17.5 inches long by 16.2 inches wide by 9.6 inches high, and weighs 21 pounds. The applicable subheading for the SPINO E1 will be 8421.21.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for liquids: For filtering or purifying water.” The general rate of duty will be free. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.24, in addition to subheading 8421.21.0000, HTSUS, listed above. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products of China, Hong Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e., 9903.01.25, in addition to subheading 8421.21.0000, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8421.21.0000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading 9903.88.01 in addition to subheading 8421.21.0000, HTSUS, listed above. The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively. The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division