RE: The tariff classification of components of a solid-fuel incineration facility from France or Turkey

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 N365781 October 23, 2026 CLA-2-84:OT:RR:NC:N1:103 CATEGORY: Classification TARIFF NO.: 8416.90.0000; 8416.30.0000 Elsa Manzanares Stinson LLP 2200 Ross Avenue, Suite 2900 Dallas, TX 75201 RE: The tariff classification of components of a solid-fuel incineration facility from France or Turkey Dear Ms. Manzanares: In your letter dated October 5, 2026, you requested a tariff classification ruling on behalf of your client, Kanadevia Inova USA LLC. The five items under consideration are components of a grate combustion system designed to generate heat for electricity production using municipal solid waste and refuse-derived fuel. While the combustion system itself is not at issue, it includes a waste delivery and storage section, a combustion and boiler section, a flue gas treatment section, an energy recovery section, and a residue handling and treatment section. The subject components are used in the combustion and boiler section. The first item is referred to as a ram feeder and is described as a ram, driven by hydraulic pistons, mounted in a frame with a sloping rear wall. It is a component of a mechanical stoker system and is used to push waste from a horizontal feed table onto an incineration grate. The second item is referred to as a grate bar and is a steel casting with a bent profile, consisting of a horizontal top section and a vertical front face. The bar is available in two configurations. The first features small, evenly spaced circular holes on the front face, whereas the second features raised circular ports or nozzles on the top surface near the front edge. The grate bars are mounted on a retaining tube to form a grate element. Alternating rows of movable and stationary grate elements make up a grate module, and multiple grate modules form a mechanical grate system that advances waste through the combustion chamber. The third item is referred to as a grate carriage and is a rigid, beam-like structure made of steel. It is a component of a mechanical grate system that connects the previously described grate bars via longitudinal links. The carriage travels forward and reverse on roller bearings along the frame, and its movement is powered by a hydraulic cylinder. The fourth item is referred to as a bottom ash chute and is described as a component of an ash discharge system that is mounted atop a bottom ash extractor. It has a downward-slanting design and is positioned below the ram feeder and grate elements. Riddling and ash are periodically conveyed to the chute, which funnels the ash into the bottom ash extractor. The fifth item is referred to as a bottom ash extractor and is described as a system used to discharge and cool residual ash and riddling. It is a self-contained unit comprising a heavy-duty steel housing, an upper inlet opening for receiving ash, an inclined trough lined with wear plates, and a lower outlet opening for material discharge. Available as either a dry or wet system, both systems are further categorized into ram-type and apron-type configurations. Ram-type systems discharge ash from an enclosed extraction chamber (for dry systems) or a water-filled hopper (for wet systems) using a hydraulically driven ram. Apron-type systems continuously discharge ash onto a fully encapsulated, air-cooled steel apron conveyor (for dry systems) or into a water-filled quench bath (for wet systems). In your submission, you suggest that the aforementioned items are classifiable under subheading 8416.90.0000, Harmonized Tariff Schedule of the United States (HTSUS). With the exception of the bottom ash extractor, we agree with the proposed subheading. In our view, the bottom ash extractor is not a component part but classified as a mechanical ash discharger. The applicable subheading for the ram feeder, grate bar, grate carriage, and bottom ash chute will be 8416.90.0000, 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: Parts.” The general rate of duty will be free. The applicable subheading for the bottom ash extractor will be 8416.30.0000, 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: Mechanical stokers, including their mechanical grates, mechanical ash dischargers and similar appliances.” The general rate of duty will be free. 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 Paul Huang at paul.huang@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division