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8418.69.01 and Section 338 Canada: Rates, Scope, and Stacking

Published: August 12, 2026  ·  6 min read
8418.69.01 and Section 338 Canada: Rates, Scope, and Stacking
Photo: Tuan Vy / Pexels

Key Points

On this page

  1. What HTS 8418.69.01 covers
  2. Base MFN rate and Column 2 rate
  3. Section 338 Canada overlay: scope and effective date
  4. Other Chapter 99 overlays cross-referenced to this code
  5. How Chapter 99 codes stack on an entry
  6. What importers should do
  7. Key references

HTS subheading 8418.69.01 covers "Other" refrigerating or freezing equipment and heat pumps under heading 8418 of Chapter 84. As of August 12, 2026, the base MFN duty rate is Free. Canadian-origin goods entered on or after August 19, 2026, are subject to additional Section 338 Canada duties reported under Chapter 99 overlay codes 9903.03.12 through 9903.03.16. The links throughout this article go to the primary documents: the proclamations, Federal Register notices, and official tariff schedule pages themselves. Read the source.

What HTS 8418.69.01 covers

Subheading 8418.69.01 sits within heading 8418 of Chapter 84 of the Harmonized Tariff Schedule of the United States (HTSUS). The article description is simply "Other," meaning it is a residual catch-all within the 8418.69 group for refrigerating or freezing equipment and heat pumps not captured by more specific subheadings. If your product falls within heading 8418 but does not match a more specific eight- or ten-digit subheading, 8418.69.01 is where it likely lands.

Confirm the precise classification for your goods against the current schedule at hts.usitc.gov. A residual "Other" description means classification disputes are relatively common, and a binding ruling from CBP may be appropriate for high-volume or high-value shipments. See our 2026 tariff code overview for broader context on the current HTSUS structure.

Base MFN rate and Column 2 rate

The Column 1 (MFN) general rate for 8418.69.01 is Free. Goods imported from countries with normal trade relations with the United States enter without any base tariff under this subheading.

The Column 2 rate is 35%. Column 2 applies only to goods originating in countries that do not have MFN status with the United States. Canadian-origin goods are not assessed under Column 2; they are assessed under the MFN column plus any applicable Section 338 or other Chapter 99 overlays.

Section 338 Canada overlay: scope and effective date

Section 338 is the trade-action program imposing additional duties on Canadian-origin goods. For entries filed on or after August 19, 2026, Canadian-origin merchandise classifiable under 8418.69.01 is subject to the Section 338 additional duty reported through Chapter 99 overlay codes 9903.03.12 through 9903.03.16.

The correct code within that range depends on the specific product and circumstances of the entry. Consult the current HTSUS Chapter 99 notes at hts.usitc.gov and CBP guidance at cbp.gov to determine which of 9903.03.12 through 9903.03.16 applies to your shipment. Do not use the 9903.03.01 through 9903.03.11 range; those codes belong to the defunct Section 122 block and are not live for Section 338 purposes.

For additional context on how Section 338 Canada operates across product categories, see our articles on 3926.40.00 and Section 338 Canada and 8517.62.00 and Section 338 Canada.

Other Chapter 99 overlays cross-referenced to this code

The HTSUS cross-references three additional Chapter 99 overlay codes to 8418.69.01. Each adds zero percent additional duty but must still be reported on the entry if applicable to the shipment.

9903.05.05: Section 301 Brazil Exemptions

Effective July 22, 2026 onward (no announced end date), 9903.05.05 provides an exemption under the Section 301 Brazil program. The duty under this overlay is "the duty provided in the applicable subheading," meaning the base MFN rate (Free in this case). Importers of goods from Brazil that qualify for this exemption must report 9903.05.05 alongside 8418.69.01 on the entry.

9903.96.01 and 9903.96.02: Civil Aircraft Exemptions

Two Civil Aircraft Exemption codes cross-reference this subheading. 9903.96.01 is effective June 30, 2025 onward (no announced end date) and carries a zero percent additional duty. 9903.96.02 is effective September 16, 2025 onward (no announced end date) and also carries a zero percent additional duty. If your goods qualify under either civil aircraft exemption, the applicable code must be reported as a separate line element on the entry. Confirm eligibility requirements in the current HTSUS Chapter 99 notes and with CBP guidance.

How Chapter 99 codes stack on an entry

Chapter 99 overlay codes do not replace the Chapter 1-97 classification. They ride alongside it. On a CBP entry, you report 8418.69.01 as the primary classification line, and each applicable Chapter 99 code (for example, the relevant 9903.03.12-16 Section 338 code) appears as its own separate line element on the same entry. The additional duties imposed by each overlay are separate from and cumulative with the base MFN rate.

Because the MFN rate here is Free, the total duty liability for a Canadian-origin shipment entered on or after August 19, 2026, equals the Section 338 rate (from the applicable 9903.03.12-16 code) plus zero from the base. But the entry mechanics still require both lines to be present. An entry that omits the Chapter 99 line is incomplete and may trigger a CBP discrepancy notice or penalty.

Use our duty calculator to model stacking scenarios for your shipments. For entry-level compliance discipline, see our article on building a monthly post-entry audit program.

What importers should do

Key references


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About the Author

Franz Brotzen, CustomsGenius CEO & Founder. Franz is a published researcher on U.S. trade policy. He has worked at think tanks in Washington DC and Tokyo, where his academic publications focussed on tariffs and legal compliance. Franz received his JD from Harvard Law School.

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