CLA-2-88:OT:RR:NC:N1:106
Valerie H. Holtrop, Managing Member
Worldwide Logistics Solutions LLC
18 Gold Wheat Lane
Wrightstown, WI 54180
RE: The tariff classification of flight simulator parts from Germany
Dear Ms. Holtrop:
In your letter dated February 4, 2012 you requested a tariff classification ruling on behalf of your client Wittenstein Arena, Inc. of Bartlett, Illinois, regarding the classification of flight simulator parts.
The items under consideration have been identified as two parts used in the construction of an Electric Control Loader (ECL) system, used with a flight simulation system which consists of pilot and co-pilot cyclic sticks, collective levers and pedal systems together with associated hardware and wiring.
You state in your request that each module set of loaders has its own force-feel characteristics controlled by a single System Control Module (SCM). The SCM communicates with the servo systems that provide the force-feel torque and movement via CAN Bus serial interface and contains the force amplifiers and Analog to Digital converters. The ECL is powered by both a 24VDC power supply unit, which provides the power for the control electronics, and a 28VDC power supply unit, which provides power for the motor. In your request you ask for classification of two items:
Control Load System (CLS)
System Control Module
Both items are used in the ECL system, which provides pilots with realistic flight control forces in a flight simulator or training device. Although you do not provide a principal use for the CLS unit you state that it is used in both commercial and military training applications. The main concept is to provide forces to the pilot using an actuator (hydraulic or electric). The approach used in high fidelity applications is to connect this actuator via a linkage to the pilot controls. The actuator is then controlled with a servo controller to control the torque or current of the motor. An outer-loop control then controls the torque provided to the pilot using a control loop around a force sensor.
The CLS system must take in inputs from the simulator and pilot and provide outputs for the pilot and simulator. Inputs are application of force and aircraft states and outputs are flight control position and forces. An aircraft with reversible controls needs to have all of the complex components modeled within the control loading system. These include cables, rods, aero forces from the control surface, centering springs and trim actuators. As the control system gets more complicated they have to simulate effects such as bob-weights and feel units. Fly-by-wire systems are disconnected from the control surfaces and so do not need the complex features but add other functionality which is simulated. The high fidelity architecture has centralized control, individual analog signals to the Control Module, a brushless DC motor with low gear ratio and linkages to the pilot controls. The modular designs have localized control and digital reporting over a field bus to the central control module. The control loading systems are designed to allow situating the actuators closer to the pilot.
The applicable subheading for the ECL components used for military applications will be 8803.21.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Aircraft…ground flying trainers...; parts…: Ground flying trainers and parts…: Air combat simulators and parts…”. The rate of duty will be Free.
The applicable subheading for the ECL components used for civilian applications will be 8803.29.0000, HTSUS, which provides for “Aircraft…ground flying trainers...; parts…: Ground flying trainers and parts…: Other”. 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 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 Matthew Sullivan at (646) 733-3013.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division