CLA-2-83:OT:RR:NC:N1:121

Mr. Russell Thornburg
Charles Dorsch Ship’s Agent, Inc.
1981 Main Street
San Diego, CA 92113

RE: The tariff classification of base metal jet ski components from Taiwan

Dear Mr. Thornburg:

In your letter dated May 6, 2013, you requested a tariff classification ruling on behalf of Rick Roy Products, Inc.

The merchandise under consideration is several base metal components used in the steering assembly of a jet ski.

Part number TR-23.5/TR-26/TR-28 is made of stainless steel and described as a Threaded Rod for RRP Handle Poles. It is threaded on both ends and smooth in the middle. They are used to secure the handlebar to the steering system of a jet ski. One end is secured into the steering system and the other end is attached to the handlebar with a nut. You have stated that the part is available in lengths of 23.5 cm, 26 cm and 28 cm.

The applicable subheading for part number TR-23.5/TR-26/TR-28 will be 7318.15.5030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: threaded articles: other screws and bolts, whether or not with their nuts or washers: studs: of stainless steel. The duty rate will be free.

Part number AL-PIV-BLT-YAM is described as a RRP Light Weight Handle Pole Pivot Bolt. The part consists of the following aluminum components: a nut, two washers and a hex head bolt. The diameters of the shank and the threads of the bolt are over 6 mm. The bolt, nut and washers are used in conjunction to secure the handle pole in the steering system of a jet ski.

The applicable subheading for part number AL-PIV-BLT-YAM will be 7616.10.7030, HTSUS, which provides for other articles of aluminum: nails, tacks, staples (other than those of heading 8305), screws, bolts, nuts, screw hooks, rivets, cotter pins, washers and similar articles: other: having shanks, threads or holes over 6 mm in diameter: threaded fasteners. The rate of duty will be 5.5% ad valorem.

Part number AL-BP-SPC/AL-BP-SPC-B is described as an RRP Aluminum Light Weight Cast Pole Spacer. It is an extruded aluminum tube with flared ends measuring approximately 5 inches long that is positioned between the handle pole and the pivot bolt. The primary function of the Cast Pole Spacer is to enclose and protect the steering components by preventing the handle pole from becoming crushed due to the load incurred while riding. Its secondary function is to minimize shock and vibrations migrating from the ski body to the handlebars. It is available in two colors; AL-BP-SPC is black and AL-BP-SPC-B is red.

The applicable subheading for part number AL-BP-SPC/AL-BP-SPC-B will be 8302.49.6055, HTSUS, which provides for base metal mountings, fittings and similar articles, other mountings, fittings and similar articles, and parts thereof, other, other, of iron or steel, of aluminum or of zinc, other, for aircraft, vessels and other vehicles (except motor vehicles) of section XVII. The duty rate will be 5.7 percent ad valorem.

Part number AL-Tube-23.5/AL-Tube-26 is described as an RRP Replacement Aluminum Tube. It is an extruded aluminum tube with a chrome finish measuring approximately 2-1/2 inches in diameter. To customize fit for the individual rider, the tube is available in two sizes; AL-Tube-23.5 measures 23.5 inches in length and AL-Tube-26 measures 26 inches in length.

The applicable subheading for part number AL-Tube-23.5/AL-Tube-26 will be 7608.20.0030, HTSUS, which provides for aluminum tubes and pipes, of aluminum alloys, seamless. The general rate of duty will be 5.7 percent ad valorem.

Your inquiry does not provide enough information for us to give a classification ruling on part number HRDP-1, described as RRP Cable Steering Hardware. Your request for a classification ruling should include a detailed explanation of where the bracket is used in the steering assembly and how it performs the function of securing components together. Identify all the components it attaches. Please explain how the included fasteners are used. Are all fasteners used with the bracket or are they also used elsewhere in the steering assembly? Are the bracket and fasteners sold in condition as imported? Are they repacked after importation? 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 including the sample of part number HRDP-1.

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 Barbara Kaiser at (646) 733-3024.

Sincerely,

Thomas J. Russo
Director
National Commodity Specialist Division