CLA-2-84:OT:RR:NC:N1:102
Ms. Nicole M. Jenkins
Crowell & Moring LLP
1001 Pennsylvania Ave. NW
Washington, DC 20004
RE: The tariff classification of an oil control valve assembly from Japan
Dear Ms. Jenkins:
In your letter dated September 29, 2010 you requested a tariff classification ruling on behalf of your client, Aisin Holdings of America, Inc.
The article in question is described as an oil control valve (OCV) assembly, part number 225400. This assembly is comprised of the following parts: solenoids, wire, sleeves, a spool valve, a ball, a shaft, bushings, springs, a spacer, an O-ring, a plunger, a cap, a stopper and a connector. Descriptive literature, illustrations and a schematic drawing were submitted.
The OCV is a solenoid operated hydraulic valve made of steel. It is specifically designed and suitable for use solely as a component of an automobile engine’s variable valve timing (VVT) system. The function of the OCV is to control the settings of the VVT by regulating the oil flow to the valves. You indicate that the OCV is connected to and controlled by an electronic control unit (ECU) which sends an electrical current that is converted into a magnetic field as it passes through the solenoid. When the oil is carried from the oil pan by the pump to the center groove of the OCV, the magnetic field shifts the spool valve from left to right which guides the oil to either the left or right side of the OCV.
The position of the engine’s camshaft depends on which direction the oil flows in the OCV. The camshaft pushes down on valves allowing fuel and air to enter past the pistons. As a result, the spark plugs ignite from the combination of fuel and air causing a small explosion. The force of the explosion pushes the pistons down which turns the crankshaft, transferring power from the engine which then makes the vehicle’s wheel rotate. The explosion caused by the piston and spark plugs creates dirty air as a by-product that must be removed before the next combustion cycle. Therefore, the timing of when the valves open and close is critical in order to remove the dirty air before the clean air enters the system.
Based on the information provided, we find that the subject OCV assembly is a solenoid type directional control hydraulic valve used in a hydraulic system and designed to control the flow of pressurized fluids for the purposes of transmitting mechanical energy.
The applicable subheading for the oil control valve (OCV) assembly will be 8481.20.0020, Harmonized Tariff Schedule of the United States (HTSUS), which provides for valves for oleohydraulic or pneumatic transmissions for directional controls, solenoid type. The rate of duty will be 2 percent ad valorem.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.
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 Kenneth T. Brock at (646) 733-3009.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division