CLA-2-39:OT:RR:NC:N2:421

Mr. Don S. Wallace
International Freight Systems of WA, LLC
19803 First Ave South, Suite 102
Seattle, WA 98148

RE: The tariff classification of silicone fittings from China

Dear Mr. Wallace:

In your letter dated March 18, 2014, on behalf of Charlie Chisholm, DBA Intakehoses.com, you requested a tariff classification ruling.

Four samples were provided with your request. All are fittings constructed of silicone plastic with embedded textile fabric reinforcement. You state that they function as connectors between two pieces of engine equipment and may be used to join the motor vehicle engine intake pipe to the throttle body assembly, air metering assembly, intercooler, blow-off valve pipe or turbo inlet/outlet. Although you describe your products both as hoses and as couplers, sleeves, reducing sleeves and reducing elbows, the samples provided with your request are all in the form of fittings rather than hoses. One sample is a 90 degree reducing elbow with a 4 inch inner diameter at one end and a 3 ½ inch inner diameter at the other end. One sample is a straight coupler/sleeve measuring 3 inches in length and 3 inches in inner diameter. One sample is a hump coupler measuring 4 ½ inches in length and 3 inches in inner diameter with a center hump. One sample is a transition coupler measuring 3 inches in length, 4 inches in inner diameter at one end and 3 inches in inner diameter at the other end. You indicate that they are marketed as replacement parts in motor vehicle internal combustion engines, but can be used in automobiles, trucks, recreational vehicles, boats or anything else with an engine.

The applicable subheading for the silicone elbow, straight coupler/sleeve, hump coupler and transition coupler will be 3917.40.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tubes, pipes and hoses and fittings therefor (for example, joints, elbows, flanges), of plastics: fittings…other. The rate of duty will be 5.3 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 Joan Mazzola at [email protected].

Sincerely,

Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division