RE: The tariff classification of portable radiant space heaters from Vietnam

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 N365568 October 19, 2026 CLA-2-84:OT:RR:NC:N1:104 CATEGORY: Classification TARIFF NO.: 8479.89.9597 John M Peterson Neville Peterson LLP One Exchange Plaza ,55 Broadway, Suite 2602 New York, NY 10006 RE: The tariff classification of portable radiant space heaters from Vietnam Dear Mr. Peterson: In your letter dated September 28, 2026, you requested a tariff classification ruling on behalf of your client, Rock Energy Systems, Inc. The products in question are three (3) models of SunFire portable radiant space heaters, models SF80, SF120, and SF160. These heaters operate by burning kerosene or diesel fuel in a combustion chamber and emitting infrared radiant energy, which heats objects and surfaces directly within a room. The heaters are not forced air heaters that heat by blowing hot air through a heat source. Model SF80 produces 80,000 BTU/hr and measures about 28 inches in height with a dry weight of 85 pounds. Model SF120 produces 120,000 BTU/hr and measures about 34 inches in height with a dry weight of 125 pounds. Model SF160 produces 160,000 BTU/hr and measures about 43 inches in height with a dry weight of 160 pounds. All units plug into a standard 120V electrical outlet. The SF80 and SF120 are wired for use with an optional thermostat, while the SF160 includes a thermostat for automatic temperature control. All units include base wheels for ease of movement. In your submission, you suggest the three portable SunFire radiant heaters are classifiable under subheading 8416.10.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Furnace burners for liquid fuel, for pulverized solid fuel or for gas; mechanical stokers, including their mechanical grates, mechanical ash dischargers and similar appliances; parts thereof: Furnace burners for liquid fuel.” We disagree. The principal function of the product is space heating. While the radiant heaters incorporate a burner assembly, they are complete, self-contained heating appliances equipped with a structural frame, fuel tank, controls, and a radiant face. Therefore, they fall outside the scope of heading 8416. The applicable subheading for the SunFire portable radiant heaters, models SF80, SF120, and SF160, will be 8479.89.9597, HTSUS, which provides for “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: 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 Arthur Purcell at arthur.purcell@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division