RE: The tariff classification of a heat exchange wall unit from Canada

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 N365179 September 29, 2026 CLA-2-76:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7616.99.5190 Michael Cantlay Twa Panel Systems 1201 4th Street Nisku, AB T9E7L3 Canada RE: The tariff classification of a heat exchange wall unit from Canada Dear Mr. Cantlay: In your letter dated September 17, 2026, you requested a tariff classification ruling. Informational material was submitted with your request. The merchandise under consideration is a heat exchange unit, identified as Twa Aluminum Plate-Fin Heat Exchange Unit 2H, used to heat the air within an indoor space. The unit is made of metal (aluminum, copper, and steel), is rectilinear in shape, and measures approximately 8 feet in length, 10 inches in height, and 7.5 inches in depth. It can be mounted on a wall or pedestal and integrated with other units powered through a building’s central boiler or heat pump system. The components include a natural convection coil (Part # COLE-84-0C1H) and metal panels that enclose the coil to distribute heat. The natural convection coil is the main component that generates the heat for this system. It consists of a copper tube enclosed by a louvered grate made of closely spaced aluminum sheet fins. It is roughly the same size and shape as the overall unit but slightly smaller because it is designed to be enclosed by the panels completing the heat exchange unit assembly. The copper tube within runs continuously along the length of the coil multiple times with its two ends extended out on one side. When heated water circulates through the copper tube, the tube heats up and transfers the heat to the aluminum fins. As this happens air passes through the fins and heats the air which is then distributed to the indoor space. In your submission, you suggest that the heat exchange unit is classifiable under subheading 8419.50.5000, Harmonized Tariff Schedule of the United States (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: Heat exchange units: Other.” We disagree. The heat exchange unit is not a machine. It is a hydronic heater that is installed to provide convective and radiant heating to indoor spaces. As such, the heat exchange unit is precluded from classification in heading 8419, HTSUS. General Rule of Interpretation (GRI) 3(b) which provides “that mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale shall be classified as if they consisted of the material or component which gives them their essential character.” In this case the component that gives heat exchange its essential character is the natural convection coil (Part # COLE-84-0C1H) because the unit cannot function without this component. We note that the convection coil is composed of more than one metal. Section XV, Note 7 of the HTSUS, states that the classification of “articles of base metal containing two or more base metals are to be treated as articles of the base metal that predominates by weight over each of the other metals.” Based on the information provided, the predominating metal in convection coil is aluminum. Thus Chapter 76, HTSUS, which provides for “Aluminum and articles thereof” is the appropriate chapter for classification. Heading 7616, HTSUS, is a residual or basket provision which covers a wide range of aluminum articles that are not more specifically provided for elsewhere in the HTSUS. The Explanatory Notes (ENs) to heading 7616 state that “This heading covers all articles of aluminum other than those covered by the preceding headings of this Chapter, or by Note 1 to Section XV, or articles specified or included in Chapter 82 or 83, or more specifically covered elsewhere in the Nomenclature.” An article of aluminum can be classified in heading 7616 if it is determined that the item is not more specifically provided for in any other heading of the tariff. The heat exchange unit is not specifically covered elsewhere in the tariff. Accordingly, they are classifiable in heading 7616, HTSUS. The applicable subheading for the heat exchange unit will be 7616.99.5190, HTSUS, which provides for “Other articles of aluminum: Other: Other: Other: Other: Other: Other.” The general rate of duty will be 2.5 percent ad valorem. 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 Matthew Gay at matthew.gay@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division