CLA-2-90:RR:NC:N1:105 K85438
Mr. Yanik Jacques
Bombarier Aerospace
400 Côte Vertu West
Dorvan, Quebec H4S 1Y9, Canada
RE: The tariff classification of Rigging Boards from Canada
Dear Mr. Jacques:
In your letter dated April 21, 2004, you requested a tariff classification ruling. No sample was submitted.
You state, “These tools are called rigging boards/tools, specially designed and customized for the Global Express aircraft wing calibration. Bombardier owns two (2) sets of these tools. The rigging boards/tools are composed of multiple 2024T3 aluminum parts and are traveling from location to location unassembled in wooden crates and on wooden skids. Once the tools are assembled, the dimension is approximately 12 feet long by 5 feet wide.
These tools are used to rig the aircraft wings. This means that the tools are used to verify and adjust the slats and flats of the wings. It allows the technician to calibrate (upwards and downwards) the moving parts of an aircraft wing. Once the tools are fixed to the wing, they act as a guide. These tools do not become part of the aircraft. They are removed after verification and calibration has been made.”
From the information you supplied, rigging boards are routinely used in maintenance. They are essentially a large template which enables the technician to see directly if the wing surfaces are in their correct position. As we understand it, if they are not, this will affect the plane’s aerodynamic properties, and the pilot may have to make adjustments to maintain level flight.
You propose classification in 9031.10.0000 as machines for balancing mechanical parts.
However, the rigging boards would not usually be considered “machines,” and Harmonized System Explanatory Note I-A-1 to 9031 states,
Machines for balancing mechanical parts (dynamic, static or with an electronic
balancing device) e.g., armatures, rotors, crank shafts, connecting rods, propeller
shafts, wheels, flywheels….
Static balancing machines operate on the tilting principle, the out-of-balance being
measured on scales or dials. They differ from dynamic machines in that the part to be
balanced does not rotate.
Your item is quite different, but it can be considered an appliance which is a Checking Standard of 9031 EN I-A-14.
The applicable subheading for your item will be 9031.80.8085, Harmonized Tariff Schedule of the United States (HTS), which provides for “other” measuring or checking instruments, appliances and machines. The rate of duty will be 1.7 percent 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 J. Sheridan at 646-733-3012.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division