Mr. Shaun Paul Simmons, President
Simports International, LLC
8212 Virginia Lane
Frederick, Maryland 21714
RE: The tariff classification of a PITLOCK® Wheel Locking System for bicycles from Germany
Dear Mr. Simmons:
In your letter dated July 17, 2001 you requested a tariff classification ruling.
You submitted a sample (Set 02/GA/BR) as well as literature describing the PITLOCK® Wheel Locking System for bicycles.
The PITLOCK system secures bicycle components to the frame by replacing conventional hardware. This system consists primarily of skewers and bolts. The skewers replace the conventional quick release skewers used to secure the wheels and seat post to a bicycle fork and frame. The bolts replace the conventional Allen key screws used to secure brakes and stems. The PITLOCK system also replaces conventional nuts with uniquely shaped locknuts that can only be opened with the matching key-like tool.
The sample (Set 02/GA/BR) you submitted consists of the following parts:
Skewers - of differing lengths for front and rear wheels and seat posts.
Pressure Washer - that assures the mounted skewer sits firmly in place.
Security Ring - is a cone-shaped element that surrounds the coded locknut in such a way that the locknut can only be opened with the matching PIT-key.
Teflon Washer - prevents the system from jamming up inside the security ring.
Coded Locknut - a coded shape that fits only inside a PIT-key of the same code. It is screwed onto the skewer with the PIT-key.
Coded PIT-key - precision milled inside in 256 different code forms.
The applicable subheading for the PITLOCK® Wheel Locking System for bicycles will be 8714.99.8000, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of vehicles of headings 8711 to 8713: Other: Other: Other. The rate of duty will be 10% ad valorem.
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 Robert DeSoucey at 212-637-7035.
Robert B. Swierupski