Ms. Lisa Regan
Lisa Regan Customs Brokerage
105 Forest Parkway
Suite 400
Forest Park, GA 30297

RE: The tariff classification of a recoil barrel system from China

Dear Ms. Regan:

In your letter dated January 22, 2014 you requested a tariff classification ruling on behalf of Simmons Imports.

The recoil barrel system, item RC2300, replaces parts of a real hand gun or pistol and is used in training. According to your letter, recoil systems are simulation devices that provide realistic recoil, sound and action for law enforcement training. The systems use inexpensive compressed gas instead of pyrotechnics. The recoil barrel system replicates the feel of shooting with a hand gun or pistol, without firing bullets. The system will be used during basic training to learn how to fire a hand gun, and to learn about the safety procedures for using a hand gun. It will also be used for shooting practice.

The recoil barrel system, item RC2300, consists of the following components: RC2310 recoil body SS316, RC2311 spring holder nylon, RC2305 valve sleeve SS316, RC2307 piston SS316, RC2308B piston pin titanium, RC2013B pin insert S7, RC2301 barrel SS316, RC2302 barrel sleeve SS316 and RC2303A barrel nose SS316. Basic operation is as follows: The gun’s firing pin hits the long firing pin extension in the recoil kit. The recoil fit firing pin then moves forward under its own inertia and strikes the valve ball bearing. The valve ball bearing moves away from the o-ring seal allowing pressurized gas to go around it. The pressurized gas drives the piston and firing pin out of the cylinder, pushing the gun slide rearward.

In your letter, you suggest classifying the recoil barrel system, item RC2300, under subheading 8479.89.9899, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other”.  By virtue of Note 1(m) to Section XVI, the Recoil Barrel RC2300 is excluded from classification in subheading 8479.89.9899, HTSUS.

The applicable subheading for the recoil barrel system, item RC2300, will be 9023.00.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for instruments, apparatus and models, designed for demonstrational purposes (for example, in education or exhibitions), unsuitable for other uses, and parts and accessories thereof. The rate of duty will be free.

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

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 Barbara Kiefer at (646) 733-3019.


Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division