N359690

N359690 April 13, 2026 OT:RR:NC:N1:102 CATEGORY: Classification; Marking; Trade Program TARIFF NO.: 8415.20.0000 Mark Neville Jr International Trade Counsellors 2153 Clementine Street Naples, FL 34120 Dear Mr. Neville: In your letter dated March 12, 2026, you requested a tariff classification and country of origin ruling for the purpose of marking on behalf of your client, Transtex LLC. You also inquire whether the unit is eligible for duty free treatment under the United States-Mexico-Canada Agreement (USMCA). The product at issue is referred to as a DClimate Truck AC Unit, part number 910016-01- HC7000U Espar RH. The unit is designed to be installed in heavy trucks for the purpose of changing temperature and humidity levels within the cabin of the truck. The unit primarily consists of a housing that features a top cover, base and an evaporator coil, a compressor, a compressor driver, a converter assembly and a condenser shroud assembly with a blower. The unit is imported packaged with a duct kit and a heater. The applicable subheading for the product will be 8415.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Air conditioning machines, comprising a motor-driven fan and elements for changing the temperature and humidity, including those machines in which the humidity cannot be separately regulated; parts thereof: Of a kind used for persons, in motor vehicles. The general rate of duty is 1.4 percent ad valorem. You explain the unit is assembled in Canada using components sourced from China. The final assembly begins by connecting suction and liquid tubes from China to the base frame, which features a Chinese sourced evaporator coil. Afterwards, an H block is installed, and a fan is fastened onto a mounting plate. Fittings for the compressor are then installed, and the tubes undergo a brazing process, followed by the mounting of a compressor assembly of Chinese origin. The process continues by connecting the refrigerant lines and bolting the vibration mounts in place. Amongst these steps, a condenser shroud assembly from China is installed into the housing and temperature sensors are installed. The respective wire connections are then completed, and the harnesses for the heater and condenser are installed and secured with clips. Afterwards, a converter sub-assembly is assembled and mounted to the unit. The input/output connectors are then installed and a microcontroller board from the United States is seated and locked in place, followed by the installation of a main electrical harness. Subsequently, the appropriate electrical connections are completed, and the fuse door is installed. Finally, the top cover is riveted onto the housing, and the unit undergoes inspections and tests. Once finished, the unit is packaged with a duct kit from China and a heater from Poland. The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note (GN) 11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b) states: For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule as a “good originating in the territory of a USMCA country” only if (i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries; (ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials; (iii) the good is a good produced entirely in the territory of one or more USMCA countries using non-originating materials, if the good satisfies all applicable requirements set forth in this note (including the provisions of subdivision (o)); As mentioned above, the final assembly of the air conditioning unit occurs in Canada using components from China. Since the subject unit contains non-originating materials, they are not considered a good wholly obtained or produced entirely in a USMCA country under GN 11(b)(i), nor is the product produced exclusively from originating materials per GN 11(b)(ii). We must therefore consider whether the merchandise qualifies as originating pursuant to GN 11(b)(iii). As noted above, the merchandise is classified in subheading 8415.20, HTSUS. The applicable product-specific rule of origin in GN 11(o)/8415.20 is underscored and requires: 50. (A) A change to subheadings 8415.20 through 8415.83 from any subheading outside that group, except from “split-systems” of subheading 8415.10, tariff item 8415.90.40 or assemblies incorporating more than one of the following: compressor, condenser, evaporator, connecting tubing; The applicable subheading rule provides that “the underscoring of the designations in subdivision 50 pertain to goods provided for in subheadings 8415.20 through 8415.83 for use in a motor vehicle of chapter 87.” Furthermore, Chapter rule 7 for goods of Chapter 84 provides that “for the purposes of the subdivisions pertaining to this chapter, whenever the subdivision designation is underscored, the provisions of subdivision (k) of this note may apply to goods for use in a motor vehicle of chapter 87.” In recognizing the product-specific rule is underscored, and the merchandise is for use in a motor vehicle of chapter 87 (namely, a heavy-truck), the provisions of subdivision (k) may apply. GN 11(k)(ii)(E)(2) includes in the definition of an “automotive good” any “part, component or material listed in table A.1, A.2, B, C, D, or E of the automotive appendix, subject to any provisions that may be included in regulations issued by the Secretary of the Treasury.” GN 11(k)(ii)(D) defines the “automotive appendix” as “. . . the Appendix to Annex 4-B of the USMCA (relating to the product-specific rules of origin for automotive goods, as reflected in subdivision (o) of this note).” Examining Table D of the automotive appendix, titled “Principal Parts for Heavy Trucks,” the subject merchandise is listed (8415.20 Air conditioning machines, comprising a motor-driven fan and elements for changing the temperature and humidity, including those machines in which humidity cannot be separately regulated, of a kind used for persons, in motor vehicles) and is for use in heavy trucks. The Note to Table D in the automotive appendix provides that “the Regional Value Content requirements set out in Article 4 of this Appendix apply to a good for use in a heavy truck.” Notwithstanding the Product-Specific Rules of Origin in Annex 4-B, each Party shall provide that the regional value content requirement for a part listed in Table D of this Appendix that is for use in a heavy truck is: (K) Notwithstanding any other provision of this note, the regional value content requirement for a part listed in Table D of the automotive appendix that is for use in a heavy truck is: (1) 60 percent under the net cost method or 70 percent under the transaction value method, if the corresponding rule in subdivision (o) of this note includes a transaction value method, beginning on July 1, 2020; (2) 64 percent under the net cost method or 74 percent under the transaction value method, if the corresponding rule in subdivision (o) of this note includes a transaction value method, beginning on July 1, 2024; and (3) 70 percent under the net cost method or 80 percent under the transaction value method, if the corresponding rule in subdivision (o) of this note includes a transaction value method, beginning on July 1, 2027, and thereafter Article 4.3 of the automotive append

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 Sandra Martinez at sandra.martinez@cbp.dhs.gov. 
Sincerely,
 (for) James P. Forkan Director National Commodity Specialist Division