CLA-2-84:OT:RR:NC:1:102
Mr. James MacNeill
MacNeill Consulting Services
P.O. Box 1214
Bristol, CT 06011
RE: The tariff classification of fuel pumps and fuel injectors from Germany.
Dear Mr. MacNeill:
In your letter dated January 21, 2014, on behalf of your client Detroit Diesel Corporation, you requested a tariff classification ruling.
The products to be imported are four different components of the fuel delivery system for a fuel-injected diesel internal combustion engine. They are referred to as a low pressure fuel pump (LPFP), a high pressure fuel pump (HPFP), a pump assembly and diesel fuel injectors.
The LPFP pulls fuel from the fuel tank and supplies it to the fuel low pressure circuit for filtering and water separation prior to delivery to the HPFP. The rotational movement of the LPFP’s gears, coupled with the design of its internal chamber, creates the suction necessary to pull the fuel from the fuel tank.
The HPFP feeds the high pressure circuit which delivers fuel through high pressure lines to the fuel rail and eventually to the fuel injectors. This pump utilizes high pressure pistons which are controlled by an integral rotating camshaft to compress the fuel. Fuel enters the piston chamber via an intake valve, and once compressed, is released from the chamber through a high-pressure valve to the fuel rail.
The pump assembly is a functional unit comprised of an LPHP and an HPFP. These fuel delivery pumps work in conjunction with each other to deliver fuel to the fuel injectors.
The diesel fuel injectors receive fuel from the HPFP via the high-pressure rail and are responsible for injecting high pressure fuel into the engine cylinders. Each injector is fitted with an amplification circuit which allows for two modes of injection; with or without amplification. You state that the mode of injection is directly correlated to the operating revolutions per minute (RPM) of the engine. If the engine RPM is below the prescribed threshold, injection occurs without amplification, and injection pressure is determined by the rail pressure. If the RPM is above the threshold injection, increased pressure is generated by operation of the amplification control module and the associated compressing action of the amplifier piston. Based on the information provided, it appears that the subject fuel injectors perform the function of a pump, as they have the ability to pressurize the fuel in the process of delivering it to the engine’s cylinders.
The applicable subheading for the LPFP, the HPFP and the LPFP/HPFP assembly will be 8413.30.9030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for pumps for liquids, whether or not fitted with a measuring device; liquid elevators; parts thereof, fuel, lubricating or cooling medium pumps for internal combustion piston engines, other, fuel pumps. The rate of duty will be 2.5 percent ad valorem.
The applicable subheading for the fuel injectors will be 8413.30.1000, HTSUS, which provides for pumps for liquids, whether or not fitted with a measuring device; liquid elevators; parts thereof, fuel, lubricating or cooling medium pumps for internal combustion piston engines, fuel-injection pumps for compression-ignition engines. The rate of duty will be 2.5 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 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 Patricia O’Donnell at (646) 733-3011.
Sincerely,
Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division