Heat Pump Imports

Heat pump imports classify under HTS 8415 (air conditioning machines incorporating refrigerating cycle) at base 2.2%. Section 122 stacks. Section 301 if China-origin. DOE energy efficiency standards apply (SEER/HSPF). EPA refrigerant regulations cover HFC and R-410A phase-down.

This guide covers U.S. import tariff and compliance for heat pumps.

For SMB importers in this category, the practical questions are HTS classification, applicable Section 232/301/122 stacks, FTA opportunities, and regulatory overlay (FDA/USDA/EPA/CPSC where relevant).

HTS classification basics

Air source heat pumps under HTS 8415.10 or 8415.81. Mini-splits under specific subheadings. Geothermal under different subheading.

Tariff stack and rates

Base 2.2% + Section 122 (15%) + Section 301 (if China-origin, often 25%). Effective 17.2-42.2%.

Country of origin considerations

China-origin (Daikin, Mitsubishi factories) dominant. Korean, Japanese alternatives. Mexican USMCA opportunities.

Regulatory overlay

DOE SEER/HSPF energy efficiency standards. EPA SNAP refrigerant approval. AHRI certification. State efficiency rebate program eligibility.

Mitigation opportunities

Korean KORUS preference. Mexican USMCA qualification. Energy-efficiency certification for state rebates supports demand.

Frequently asked questions

What is the typical effective duty rate?

Depends on origin and HTS classification. China-origin: 22-42% effective when Section 301 + Section 122 stack. USMCA-qualifying Mexican production: often 0-3%. Vietnam, India, Korea: 15-17% with Section 122.

Can I qualify under USMCA?

Possible if production occurs in U.S., Mexico, or Canada and meets rules of origin (typically 60% RVC under transaction value or 50% net cost). USMCA-qualifying goods are exempt from Section 122.

Are IEEPA refunds available?

Yes – for entries between April 5, 2025 and February 24, 2026 that paid IEEPA duty. Filed through CBP’s CAPE portal. We file claims on contingency for filings above $50k.

What about Section 232 exposure?

Specific to product type. Steel and aluminum derivatives expansion brought some downstream products into scope. Component-level analysis identifies actual coverage.

How do you help with this category?

Tariff exposure assessment ($2,500-$7,500), classification audit, USMCA qualification, refund recovery, audit response. Independent of any customs brokerage.