The tariff classification of dishwashers from China

N361453June 2, 2026CLA-2-84:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 8422.11.0000 J. Michael TaylorKing & Spalding LLP1700 Pennsylvania Ave NW, Suite 900Washington, DC 20006RE: The tariff classification of dishwashers from ChinaDear Mr. Taylor:In your letter dated May 11, 2026 , on behalf of your client, Electrolux Group, you requested a tariffclassification ruling. Descriptive literature was provided for our review.The items under consideration are described as dishwashers that you state are specially designed for thehandicapped (individuals who are wheelchair-bound) and require access to low countertop surfaces. Thedishwashers are imported in three colors, each with their own model number. The FFBD2420UB representsthe black version, the FFBD2420US represents the stainless-steel version, and the FFBD2420UW representsthe white version. A dishwasher is an automated appliance that cleans, sanitizes, and dries dishes, cutlery,and cookware using a combination of hot water, specialized detergent, and pressurized spray arms. Itoperates by filling with water, heating it, spraying dishes to remove food, draining the dirty water, rinsing,and drying, which is more water-efficient than handwashing. The dishwashers measure 32 2/5 inches inheight, 24 inches in width, and 24 inches in depth. For reference, a full-sized dishwasher measures 34 to 35inches in height.The dishwashers are manufactured in accordance with specifications required by the Americans withDisabilities Act (ADA), such as: (1) maximum high forward reach for controls and operating mechanisms of48 inches, (2) maximum low forward reach of 15 inches, (3) controls and operating mechanisms that areoperable with one hand and do not require tight grasping, pinching, or twisting of the wrist, (4) controls thatmay be activated by a force of no more than 5 pounds, and (5) all rack space accessible from the front of themachine for loading and unloading dishes.The applicable subheading for the dishwashers (models FFBD2420UB, FFBD2420US, FFBD2420UW) willbe 8422.11.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for“Dishwashing machines; machinery for cleaning or drying bottles or other containers; machinery for filling,closing, sealing or labeling bottles, cans, boxes, bags or other containers; machinery for capsuling bottles, jars, tubes and similar containers; other packing or wrapping machinery (including heat-shrink wrappingmachinery); machinery for aerating beverages; parts thereof: Dishwashing machines: Of the household type.”The general rate of duty will be 2.4 percent ad valorem.In your submission you request consideration of a secondary classification for the subject dishwashers under9817.00.96, HTSUS, which applies to articles and parts of articles specially designed or adapted for the useor benefit of the permanently or chronically physically or mentally handicapped. Chapter 98, SubchapterXVII, U.S. Note 4(a), HTSUS, defines the term “blind or other physically or mentally handicapped persons”as including “any person suffering from a permanent or chronic physical or mental impairment whichsubstantially limits one or more major life activities, such as caring for one’s self, performing manual tasks,walking, seeing, hearing, speaking breathing, learning, or working.” You state that the dishwashers at issue are specially designed to service the specific needs of the same classof permanently handicapped people that require a wheelchair. Therefore, in your opinion, the dishwashers arespecially designed for permanently handicapped people who are unable to walk or move without theassistance of a wheelchair. While these dishwashers are ADA compliant and may benefit individuals in wheelchairs, their utility extendsto those with limited kitchen space. They offer full functionality comparable to standard dishwashers, despitea slightly smaller footprint. This makes them suitable for a broad range of applications beyond thosespecifically designed for individuals with mobility constraints. Furthermore, these dishwashers are availablethrough standard home improvement retailers, without requiring special prescriptions orauthorizations. Therefore, in our opinion, the dishwashers do not satisfy the description set forth in Chapter98, Subchapter XVII, U.S. Note 4(a). Accordingly, the secondary classification will not apply to thedishwashers (models FFBD2420UB, FFBD2420US, FFBD2420UW) under 9817.00.96, HTSUS.The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenienceand are subject to change. The text of the most recent HTSUS and the accompanying duty rates are providedat 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 theclassification 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for)James P. ForkanDirectorNational Commodity Specialist Division