CLA-2-84:RR:NC:MM:106 G87860
Mr. Joseph P. Cravero
Deere & Company Tax Department
One John Deere Place
Modine, IL 61265
RE: The tariff classification of John Deere SST16 and SST18 lawn tractors and a steering/drive transaxle.
Dear Mr. Cravero:
In your letter dated February 23, 2001 you requested a tariff classification ruling. You submitted descriptive literature with your request.
The John Deere SST16 and SST18 lawn tractors are four-wheeled, self-propelled tractors that utilize "Spin-Steer" technology. The SST16 has a 16hp (11.9 kw) V-Twin Briggs & Stratton Vanguard air-cooled engine and the SST18 has an 18hp (13.4 kw) V-Twin Briggs & Stratton Vanguard air-cooled engine. Both models have a foot-controlled implement lift system and each model is equipped with an electric PTO clutch operated from the dash.
Both tractors have a Kanzaki Transaxle, which is made in Japan. The SST transmission encloses 2 hydrostatic systems in the same housing for steering and drive. The steering system is connected to the drive system through reduction gears. Forward speed is controlled by a foot level, while the turning radius is controlled by the steering wheel and ground speed. Since the transaxle is not merely a transmission but a combination of steering and drive systems, it is more than a mere transmission.
The SST16 model is equipped with a 42 All Purpose Mower Deck or a 42M Mulching Freedom Mower Deck. The SST18 model is equipped with a 48C Convertible Mower Deck. Both models can accommodate a variety of implements such as mulching attachments, rear baggers, 54-in-tow-behind thatcherator, aerator spreaders, lawn rollers and utility carts. The John Deere SST16 and SST18 lawn tractors are ride-on mowers that are utilized on lawns or sports field facilities.
The applicable subheading for the John Deere SST16 and SST18 lawn tractor will be 8433.11.0040, Harmonized Tariff Schedule of the United States (HTS), which provides for riding mowers for lawns, parks or sports grounds: other than electric: 7.46 kW and over. The rate of duty will be free.
The applicable subheading for the Kanzaki transaxle will be 8433.90.1000, HTS, which provides for parts of mowers for lawns, parks or sports grounds. 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
Patrick J. Wholey at 212-637-7036.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division