CBP Proposes to Revise Rulings on Classification, Duty-Free Treatment

The following proposed revocations or modifications of U.S. Customs and Border Protection rulings are included in the Feb. 18, 2026, Customs Bulletin and Decisions. Comments on these proposed changes are due by March 20.

For more information on how to seek or utilize classification and other rulings, please contact ST&R.

Automobile Coolant Heaters

CBP is proposing to reclassify automotive coolant heaters as other heating machinery under HTSUS 8419.89.95 (4.2 percent duty) rather than as heat exchange units under HTSUS 8419.50.50 (duty-free). Rulings HQ H065718, HQ H065720, and NY N233110 would be revoked to reflect this change.

The items at issue are auxiliary heating systems used to heat and regulate heated coolant flow to a vehicle’s interior, engine, and fuel tank. They operate by drawing fuel from the vehicle’s tank into a combustion chamber. Simultaneously, a pump circulates cold engine coolant into the chamber, where a heat exchanger heats it. The hot coolant is circulated back through the vehicle’s engine and HVAC heat exchanger.

CBP explains that the most important attribute when identifying a heat exchanger (or heat exchange unit) is the physical contact between two closed systems that results in a desired temperature change in the fluid traversing through one component and an accompanying necessary temperature change in the fluid traversing through the other component. In this case, however, the subject devices simply heat cold engine coolant that is then used to warm automobile engines and air that is distributed to automobile passenger compartments.

Prosthesis Alignment Systems

In ruling NY A85213 CBP determined that a titanium alignment system for below-the-knee modular limb prostheses (1) is classified as a part for artificial body parts under HTSUS 9021.30.0000 but (2) is ineligible for duty-free treatment under HTSUS 9817.00.96. CBP is now proposing to modify that ruling and hold that the system is eligible for such treatment.

The item at issue consists of a 30mm diameter tube adaptor with integrated four-screw alignment head and sliding adaptors for either a laminate or thermoplastic socket.

HTSUS 9817.00.96, which implements the Nairobi Protocol, provides for duty-free treatment for “articles specially designed or adapted for the use or benefit of the blind or other physically or mentally handicapped persons.” CBP now proposes to hold that the alignment system at issue meets all five of the factors it uses to determine whether articles meet that description.