RE: The tariff classification of two electric hot tubs from the United Kingdom

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 N365099 October 1, 2026 CLA-2-90:OT:RR:NC:N3:143 CATEGORY: Classification TARIFF NO.: 9019.10.2045 Christian Galley Tubmarine The Old Sawmills Middlemarsh Middlemarsh DT9 5QW United Kingdom RE: The tariff classification of two electric hot tubs from the United Kingdom Dear Mr. Galley: In your letter dated September 16, 2026, you requested a tariff classification ruling. The products under consideration are the Tubmarine Two-Person and Four-Person Electric Hot Tubs. Both models are imported fully assembled, complete, freestanding, and fully insulated hot tubs. They are the same type of product but differ in size, water capacity, and number of hydromassage jets. Each hot tub features a marine-grade 316 stainless-steel bathing shell and exterior surfaces, Kebony timber cladding, an integrated electric water heater, a powered water-pumping system, a filtration system, digital touchscreen controls, directional hydromassage jets, ambient lighting, insulation, adjustable feet, and an integrated drain valve. Both models operate from a dedicated mains electrical supply, are not battery powered, do not operate through an external AC adapter, and are intended for year-round outdoor use. The two-person electric hot tub incorporates 12 powered directional hydromassage jets, while the four-person electric hot tub incorporates 24 powered directional hydromassage jets. The two-person model has external dimensions of approximately 2038 mm by 1544 mm by 1015 mm, a water capacity of 700 liters, and an approximate filled weight of 1,350 kg. The four-person model has external dimensions of approximately 2038 mm by 2014 mm by 1015 mm, a water capacity of 1,100 liters, and an approximate filled weight of 1,850 kg. Each model also incorporates a 3-kW electric heater that heats the water and automatically maintains the selected temperature. The touchscreen control panel operates both the temperature settings and the hydromassage jets. The filtration and circulation functions maintain the condition of the water, while the separate powered directional jets provide the full-body massage function. Users can direct the jets toward different areas of the body and adjust the pressure to their preference. You state that the directional jets are purpose-designed and positioned to provide a targeted full-body water massage for the occupants. In your submission, you suggest the tariff classification for the Tubmarine Two-Person and Four-Person Electric Tubs under the subheading 9019.10.2045, Harmonized Tariff Schedule of the United States (HTSUS). We agree. The applicable subheading for the Tubmarine Two-Person and Four-Person Electric Tubs will be 9019.10.2045, HTSUS, which provides for “mechano-therapy appliances; massage apparatus …: massage apparatus: electrically operated: other: other.” The general rate of duty will be free. The 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/. 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 Dionisia Melman at dionisia.y.melman@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division