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February 16, 1999

CLA-2-84:RR:NC:1:104 D87523

CATEGORY: CLASSIFICATION

TARIFF NO.: 8418.69.0095

Ms. Susan Rams
Clearfreight, Inc.
880 Apollo Street, Suite 101
El Sequndo, CA 90245

RE: The tariff classification of thermoelectric coolers from Hong Kong

Dear Ms. Rams:

In your letter dated January 21, 1999 on behalf of Tom McSpadden you requested a tariff classification ruling.

The COOLY Calypso portable thermoelectric cooler Model CC-20V-12/24 has the ability to cool and to heat. With a capacity of 20 liters and a standing height for 1.5 liter bottles, the unit has ample space for food/drink. The cooler features full polyurethane foam insulation. The automatic changeover to 12/24 volts makes it ideal for travel (e.g., truckers, private cars, etc.).

By utilizing the Peltier effect, the unit can be switched from cold to warm. This principle, on which thermoelectic refrigeration is based, allows the transfer of heat energy from one place to another using electrons instead of a refrigerant. A fan expels the hot air from the insulated cabinet. Reversing the flow of current causes warm air to be drawn into the cabinet rather than expelled, thereby warming the food stored therein. Maximum cooling performance is approximately 20oC below ambient temperature while the inside temperature cut-off by thermostat in the heating mode is +65o C. These units are bought primarily for their cooling capability and are principally used to refrigerate rather than heat food.

The applicable subheading for the thermoelectric coolers will be 8418.69.0095, Harmonized Tariff Schedule of the United States (HTS), which provides for Refrigerators, freezers and other refrigerating or freezing equipment, electric or other; heat pumps, other than the air conditioning machines of heading 8415; parts thereof: Other refrigerating or freezing equipment: Other. The rate of duty will be free.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Robert Losche at 212-637-7038.

Sincerely,

Robert B. Swierupski
Director,

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