CLA-2-84:OT:RR:NC:1:104
Mr. Kevin Anderson
RS Technical Services Inc.
1327 Clegg Street
Petaluma, CA 94954
RE: The tariff classification of the TranSTAR from the United States
Dear Mr. Anderson:
In your letter dated March 8, 2012 you requested a tariff classification ruling.
The TranSTAR Transporter Model #032-02500 is designed to carry the Omni Eye III and NovaSTAR cameras through sewers or fresh water pipe lines. The TranSTAR is available in various configurations according to the customer’s specifications. Options include rear view cameras, manual and motorized elevator systems and multiple tire options. Capable of travelling up to 80 feet per minute, the model has three forward speeds and one reverse speed. The basic TranSTAR weighs 25 lbs. with wheels but no camera. It is 4.5 inches in height with stock tires. Features include a 90 W, coreless DC motor and an internal gear drive. It has a maximum distance of up to 2500 feet. Distance varies with cable and line conditions.
An operator attaches a camera unit and power cable to the TranSTAR. The combination is then inserted into a sewer or water pipe. Using a desktop or hand held controller, it is controlled remotely from above ground. The cable delivers power, control signals, transmits video and retrieves the unit. The TranSTAR’s only function is to move the camera through the pipe. The purpose of this video inspection system (TranSTAR, camera, and cable) is to perform visual inspection of the sewer and water pipes in order to identify defects.
The applicable subheading for the basic TranSTAR without camera or camera lift will be 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”. The general duty rate will be 2.5 percent ad valorem.
The applicable subheading for the TranSTAR equipped with the camera lift but no camera will be 8427.10.8060, HTSUS, which provides for other works trucks fitted with lifting or handling equipment: self-propelled trucks powered by an electric motor: other… automated guided vehicle (AGV). The general duty rate 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/.
You suggested that the TranSTAR be classified in subheading 8705.90.0000, HTSUS, which provides for “Special purpose motor vehicles, other than those principally designed for the transport of persons or goods … : Other.” However, this item is excluded from classification under subheading 8705.90.0000, HTSUS, by virtue of Explanatory Note (III)(12) to heading 8479, HTSUS. Said note states that machines for the maintenance of pipelines or other non-flexible pipes, such as small self-propelled machines used on oil pipelines to clean the pipe, are classifiable in heading 8479, HTSUS.
Your inquiry does not provide enough information for us to give a classification ruling on other possible configurations. Your request for a classification ruling should include details on the specific configurations to be considered. When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you. Please limit your ruling request to a maximum of 5 items of the same class or kind.
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 Patricia O’Donnell at (646) 733-3011.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division