CLA-2-73:OT:RR:NC:1:118

Mr. Sebastian Eich
Aventis Atlantic Partners LLC
245 N. Highland Ave NE
Suite 230-102
Atlanta, GA 30307

RE: The tariff classification of a helical spring and a magnetic housing from Germany.

Dear Mr. Eich:

In your letter dated April 3, 2014, on behalf of Rausch & Pausch LP, you requested a tariff classification ruling on two parts of a solenoid valve.

Part number 16418 001, described as a compression spring, is a helical wire spring made of steel. The wire that the spring is made of has a cross-sectional dimension of 5.8 mm. You have stated that the force of the compression spring brings an actuator pin to a defined position within the solenoid valve. Part number 16411 001 is described as a magnetic housing. It is constructed of steel and manufactured though a rolling process. The item weighs 12.8 grams and measures 23 mm in diameter and 27.5 mm in height. It is stated that the magnetic housing is part of the magnetic circuit within the solenoid valve and conducts the magnetic flux.

The applicable subheading for the compression spring, part number 16418 001, will be 7320.20.5045, Harmonized Tariff Schedule of the United States (HTSUS), which provides for springs and leaves for springs, of iron or steel: helical springs: other: helical springs, of wire having a cross-sectional dimension of 5.1 mm or more but less than 12.7 mm. The duty rate will be 3.9% ad valorem.

The applicable subheading for the magnetic housing, part number 16411 001, will be 8481.90.9040, HTSUS, which provides for other parts of taps, cocks, valves and similar appliances of subheading 8481.20. The rate of duty is free.

You suggested classifying the compression spring, part number 16418 001, within subheading 7320.20.5060, HTSUS. However, that subheading provides for helical springs with cross-sectional dimensions of 12.7 mm or greater. The helical spring under consideration has a cross-sectional dimension of less than 5.8 mm. Therefore, your proposed classification is incorrect.

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 Anthony Grossi at [email protected].

Sincerely,

Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division