Water-cooled packaged air conditioner HTSUS 8415.82.0110: U.S. import guide 2026

Classification conclusion

A complete 115 kW water-cooled packaged air conditioner precharged with 32 kg R407C may enter under HTSUS 8415.82.0110. Review DOE certification, EPA HFC controls and China-origin Chapter 99 duties.

Quick answer

The merchandise is a complete self-contained, water-cooled commercial or industrial air-conditioning machine, model KH040D-CS, rated at 115 kW cooling capacity and imported with 32 kg of R407C. On the stated facts, HTSUS 8415.82.0110 is the leading U.S. reporting-number candidate because the unit incorporates a refrigerating unit, exceeds 17.58 kW and is not shown to use a reversible-cycle valve.

This conclusion is conditional. If the PTC heater makes the entered machine a year-round heating and cooling unit within the statistical breakout, 8415.82.0120 must be tested instead. The importer should obtain the wiring diagram, refrigeration circuit and manufacturer statement before entry.

Classification under the HTSUS

Heading 8415 covers air-conditioning machines comprising a motor-driven fan and elements for changing temperature and humidity. The compressor, evaporator and water-cooled condenser establish an incorporated refrigerating unit. GRI 1 places the complete machine in heading 8415; GRI 6 selects subheading 8415.82 because the record does not establish a reversible-cycle valve required by 8415.81.

The proposed entry description is: “Self-contained water-cooled commercial/industrial air-conditioning machine, model KH040D-CS, 115 kW cooling capacity, 380V/3N~/50Hz, airflow 16,800 m³/h, precharged with 32 kg R407C, new.” Do not describe the unit as uncharged unless the manufacturer documents complete refrigerant recovery before export.

U.S. duty and China-origin measures

The 2026 HTSUS Column 1 general rate for 8415.82.01 is 2.2%. For China-origin merchandise, the exact eight-digit subheading and entry date must also be tested against Chapter 99. As reviewed on September 11, 2026, the stated line is subject to the China technology-transfer action under 9903.88.03 at an additional 25% and the separate forced-labor action under 9903.05.31 at an additional 12.5%, unless a valid exclusion or specific exception applies.

MPF and, for ocean entries, HMF remain separate. A landed-duty total cannot be finalized without transaction value, origin, entry date, exclusion status, and a written-scope search for antidumping or countervailing duty proceedings.

DOE energy-conservation requirements

Water-cooled unitary air conditioners are covered commercial equipment under Part A-1 of Title III of EPCA. The importer is treated as a manufacturer for DOE compliance purposes. Before importation and distribution, verify the equipment class, cooling capacity, test procedure, applicable energy-conservation standard, certification status and basic model under 10 CFR Part 431, including sections 431.92, 431.96 and 431.97.

Customs release does not replace DOE certification. Obtain rated cooling capacity, efficiency metrics, test reports, certification data and the exact basic-model identity before shipment.

R407C and EPA HFC controls

R407C is an HFC blend. EPA allowance requirements generally apply to the import of bulk HFCs, not solely because a finished product is precharged. A precharged product may nevertheless be subject to AIM Act Technology Transitions restrictions, labeling, recordkeeping and reporting rules.

For this 115 kW commercial unit, determine its regulatory subsector, manufacture date and installation configuration under the EPA rule in force on the entry date. Preserve the refrigerant identity and charge, production date, supplier declarations, quota-related records where applicable, and required product labels. Do not state that R407C is unrestricted merely because the equipment is complete.

Origin, marking and forced-labor due diligence

Mark the actual country of origin under 19 U.S.C. 1304 and 19 CFR Part 134. Country of shipment is not necessarily country of origin. For China-origin machinery, retain component sourcing, assembly, factory and payment records sufficient for UFLPA and other supply-chain screening where relevant.

Documents to obtain before entry

• Complete technical catalogue, refrigeration schematic and wiring diagram.
• Nameplate showing model, voltage, cooling capacity, airflow, R407C and 32 kg charge.
• Statement addressing reversible-cycle operation and year-round heating/cooling.
• DOE equipment-class, test, certification and basic-model records.
• EPA AIM Act subsector, manufacture-date, labeling and HFC records.
• Producer, exporter, origin, valuation and current Chapter 99 analysis.
• Written-scope search results for AD/CVD and any applicable exclusions.

Official sources

• USITC Harmonized Tariff Schedule
• U.S. Department of Energy: Water-Cooled Unitary Air Conditioners
• DOE importer compliance questions and answers
• EPA HFC phasedown frequently asked questions
• EPA Technology Transitions regulatory actions
• USTR Section 301 tariff search

2026 U.S. customs and import-law review

Legal review date: September 5, 2026. The USITC online HTSUS identified 2026 Revision 18 on this review date. Rates and Chapter 99 measures can change during the year, so the legally operative schedule is the edition in effect on the entry date.

1. Quick legal conclusion

The proposed reporting number is 8415820110 for Self-contained air-conditioning machines exceeding 17.58 kW, but only for merchandise that matches this defined scope: A complete new self-contained water-cooled commercial or industrial air-conditioning machine, model KH040D-CS, with motor-driven fan, compressor, evaporator, water-cooled condenser, 115 kW cooling capacity and 32 kg R407C precharge. This is a fact-dependent classification opinion, not a CBP ruling and not a determination of admissibility, origin or AD/CVD scope.

2. Facts that must be verified before entry

• Refrigeration circuit, reversible-cycle valve and role of the PTC heater
• Cooling capacity, rated input, voltage, airflow and water-cooled condenser
• R407C composition, 32 kg charge, manufacture date, origin and complete condition

Also obtain the complete bill of materials, technical drawings, model numbers, operating manual, condition and configuration as imported, transaction chain, manufacturer/producer, country of origin of material inputs and intended U.S. use. A material difference requires a new analysis.

3. HTSUS analysis and controlling authority

• GRI 1 places the complete air-conditioning machine in heading 8415; GRI 6 selects 8415.82 because it incorporates a refrigerating unit and no reversible-cycle valve is established.
• Cooling capacity and national statistical breakouts determine the final country code: 115 kW exceeds the relevant 26.38 kW, 17.58 kW and 4,000 kcal/h thresholds.

The analysis must begin with GRI 1, the heading text and binding Section/Chapter Notes, then proceed to GRI 2–5 only if legally necessary and to GRI 6 for subheadings. U.S. Additional Rules of Interpretation and Additional U.S. Notes are controlling where applicable. WCO Explanatory Notes are persuasive interpretive material but are not U.S. statutory text. A CROSS ruling is binding only for the requester and merchandise covered by its facts; materially similar rulings may be persuasive. CIT and Federal Circuit decisions control within their jurisdiction.

Goods outside this opinion include:

• Reversible-cycle heat pumps, split-system components, chillers, fan-coil units, replacement condensers, uncharged incomplete units and separately imported parts require separate classification.

For recurring or high-value entries, request a prospective binding ruling from CBP under 19 CFR Part 177 and disclose all material facts. A ruling request is not a substitute for checking post-ruling HTSUS amendments or trade remedies.

4. Duty, fee and tax matrix

This table does not calculate landed cost. The importer must also determine customs value under 19 U.S.C. 1401a, including assists, packing, royalties/license fees, proceeds and related-party acceptability. A “first sale” claim requires a bona fide sale for export to the United States, arm's-length evidence and a complete transaction trail.

5. AD/CVD and evasion review

For China-origin merchandise, test HTSUS 8415.82.01 against every applicable Chapter 99 note and exclusion on the entry date. The reviewed measures include 9903.88.03 at 25 percent and 9903.05.31 at 12.5 percent; origin, product scope and effective date must still be documented. Separately search current AD/CVD written scopes by product, producer and exporter.

The written scope description is dispositive; an HTSUS number in an order is only a convenience reference. If coverage is uncertain, obtain a Commerce scope ruling under 19 CFR 351.225 before relying on a non-covered position. Minor processing or assembly in a third country can trigger a circumvention analysis. False origin, undervaluation or evasion can lead to EAPA investigation under 19 U.S.C. 1517 and civil penalties under 19 U.S.C. 1592.

6. Partner Government Agency and product compliance

Water-cooled unitary air conditioners are covered commercial equipment under DOE rules in 10 CFR Part 431; the importer is treated as a manufacturer for EPCA compliance. A unit precharged with R407C also requires an EPA AIM Act Technology Transitions, labeling, recordkeeping and reporting assessment. Bulk-HFC allowance rules and rules for products containing HFCs must not be conflated.

PGA admissibility is independent of tariff classification. Transmit all required agency data and documents through ACE; a CBP release does not cure a violation of an FDA, CPSC, EPA, FCC, DOT, USDA or other agency rule.

7. Origin, marking and UFLPA

Determine nonpreferential origin under the substantial-transformation test and any product-specific rule; do not rely only on the shipping country, invoice origin or location of final packing. Mark the article and, when required, its container under 19 U.S.C. 1304 and 19 CFR Part 134, unless a documented exception applies. Section 301, AD/CVD, government procurement and a preference program may use distinct origin rules.

Under 19 U.S.C. 1307 and the UFLPA, goods mined, produced or manufactured wholly or in part in Xinjiang, or by an entity on the UFLPA Entity List, are subject to a rebuttable presumption of exclusion. Maintain supplier identity, production, payment, logistics and input-tracing evidence; a generic supplier declaration is not enough for a high-risk supply chain.

8. Minimum entry file

• CBP entry/cargo release data and Form 7501 record, customs bond, commercial invoice, packing list and bill of lading/air waybill.
• Purchase orders, payment records, Incoterms, assists/royalties analysis and related-party or first-sale valuation support.
• Product specifications, drawings, photographs, manuals, composition/BOM, model cross-reference and condition as imported.
• Signed classification memorandum applying the GRIs, legal notes, current HTSUS text and relevant rulings, plus rejected alternatives.
• Origin and marking analysis; producer/supplier affidavits and traceability records; Chapter 99 and exclusion support.
• AD/CVD scope search, producer/exporter case numbers and cash-deposit instructions, even when the conclusion is “not covered.”
• All PGA registrations, certificates, laboratory reports, licenses, notices and ACE data required for this product.

Keep entry and supporting records for the statutory period, generally five years, under 19 U.S.C. 1508 and 19 CFR Part 163.

9. Principal legal risks

• Declaring a 10-digit number from the trade name without proving the imported condition and legally relevant characteristics.
• Omitting a Chapter 99 number or calculating only the Column 1 rate.
• Treating an AD/CVD HTS cross-reference as dispositive instead of reading the written scope.
• Using shipping country as origin without a substantial-transformation and marking analysis.
• Filing before PGA admissibility, certificates, laboratory evidence or supply-chain traceability are complete.

An incorrect entry can produce redelivery, exclusion/seizure, duty reassessment, interest, loss of liquidation defenses and penalties. If past entries contain a material error, promptly evaluate a post-summary correction, protest, prior disclosure under 19 CFR 162.74 or other corrective procedure with U.S. customs counsel; the correct route depends on entry and liquidation status.

10. Pre-entry action checklist

1. Lock the specifications and imported configuration for the exact SKU. 2. Re-run classification against the current HTSUS and record GRI/Note reasoning. 3. Determine customs value, nonpreferential origin and marking. 4. Screen Chapter 99, Section 301/232, quota/safeguard and every potentially relevant AD/CVD scope. 5. Complete the product-specific PGA review and obtain supporting certificates before shipment. 6. Calculate landed duties and fees, then have the importer and licensed customs broker validate ACE reporting. 7. For unresolved or commercially material classification issues, obtain a CBP Part 177 ruling before importation.

Official legal sources

• United States International Trade Commission; HTSUS 2026: Harmonized Tariff Schedule of the United States
• U.S. Department of Energy; 10 CFR Part 431: Water-Cooled Unitary Air Conditioners
• U.S. Environmental Protection Agency; AIM Act: Technology Transitions regulatory actions
• USITC — Current Harmonized Tariff Schedule of the United States
• CBP — User fee table: MPF rate and FY 2026 minimum/maximum
• CBP — Harbor Maintenance Fee
• CBP — ACE: filing customs and Partner Government Agency data
• USTR — Section 301 tariff actions and exclusion search
• BIS — Section 232 steel and aluminum measures
• Commerce — AD/CVD FAQs, scope and circumvention rules
• Commerce — ACCESS AD/CVD proceeding search
• CBP — UFLPA rebuttable presumption
• CPSC — Certificates and mandatory eFiling guidance
• FDA — Importing food products into the United States
• EPA — TSCA requirements for importing chemicals
• PHMSA — Lithium battery transportation requirements
• FCC — Equipment authorization
• eCFR — 19 CFR Part 177: administrative rulings
• eCFR — 19 CFR Part 134: country-of-origin marking
• eCFR — 19 CFR Part 163: recordkeeping

> Legal notice: This article provides general U.S. customs and trade-compliance information based on the stated facts as of September 5, 2026. It is not a CBP, Commerce or PGA ruling and is not legal advice for a specific transaction. Current HTSUS/Chapter 99 text, agency requirements and case-specific AD/CVD instructions must be rechecked at entry.

Editorial note

Prepared by the Global HS Code Checker Editorial Team for customs-classification, tariff and import-policy research. The correct code and applicable measures may change with the merchandise's actual characteristics, jurisdiction, entry date and supporting record. Verify the current tariff, governing measures and competent customs authority before filing an entry. A reviewer is identified only after a named expert has completed the review.