Ms. Debbie Brule
Global Transportation Services Inc.
18209 80th Avenue South, Suite A
Kent, WA 98032
RE: The tariff classification of Bucket Grubbers and a Bucket Mount from China and Taiwan
Dear Ms. Brule:
In your letter dated September 22, 2017, on behalf of BAC Industries Inc., you requested a tariff classification ruling. In response to our request for additional information, our office received answers to our questions in your letter dated October 27, 2017. Photographs, descriptive literature and operating instructions for the subject articles were submitted for our review.
The articles under consideration are identified as the BG-21 Bucket Grubber, the BG-22 Bucket Grubber HD and the BG-23 Bucket Mount. The Bucket Grubbers and Bucket Mount are used in agriculture, horticulture or forestry for brush and tree removal. You stated in your letter that “BG-21 and BG-22 are steel fixed jaw products meant to be mounted to the bucket of a skid steer loader or tractor using the BG-23 Bucket Mount. The Bucket Grubbers grab onto brush and small trees so that the skid steer loader can pull them from the ground. The BG-23 Bucket Mount is a steel clamp that mounts the BG-21 or BG-22 to the skid steer loader bucket. Neither BG-21 nor BG-22 can operate without this mount.”
The descriptive literature indicates that the BG-21 Bucket Grubber features 33 no slip grip teeth per grip bar, and handles brush and stumps up to 2.5 inches in diameter. The BG-22 Bucket Grubber HD features 14 no slip grip teeth per grip bar, and handles brush and stumps up to 4 inches in diameter. Both Bucket Grubbers remove unwanted brush and trees including the roots. The BG-23 Bucket Mount is made of heavy duty 3/4 inch steel, and features a unique universal clamp that fits most skid loader and tractors buckets. The BG-23 Bucket Mount is required to operate the BG-21 Brush Grubber and the BG-22 Brush Grubber HD.
You suggested classification for the subject Bucket Grubbers and Bucket Mount under heading 8431, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts suitable for use solely or principally with the machinery of headings 8425 to 8430. The Bucket Grubbers and Bucket Mount have neither mechanical nor electrical features. In addition, they are not integral and constituent components of a skid steer loader without which the loader could not operate. They are more in the nature of accessories. The language of heading 8431 only provides for parts. Thus, we would not consider the BG-21 Bucket Grubber, the BG-22 Bucket Grubber HD and the BG-23 Bucket Mount to be classifiable in heading 8431, HTSUS.
The applicable subheading for the BG-21 Bucket Grubber, the BG-22 Bucket Grubber HD and the BG-23 Bucket Mount will be 7326.90.8688, HTSUS, which provides for other articles of iron or steel, other…other. The rate of duty will be 2.9 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 https://hts.usitc.gov/current.
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 Ann Taub at [email protected]
Steven A. Mack
National Commodity Specialist Division