CLA-2-87:OT:RR:NC:N1:106
James MacNeill, Senior HTS Classification Analyst
MacNeill Consulting Services
P.O. Box 1214
Bristol, CT 06011-1214
RE: The tariff classification of pipes for vehicle exhaust systems from Germany
Dear Mr. MacNeill,
In your letter dated November 10, 2014, you requested a tariff classification ruling on behalf of Daimler Trucks North America of Portland, Oregon. The items under consideration have been identified as a Turbo Outlet Pipe (Part # A04-26053), an Exhaust Bellows (Part # A04-25021) and an Exhaust Elbow Pipe (Part # 04-27790).
In your request, you stated that the Turbo Outlet Pipe (Part # A04-26053) is a bent to shape pipe designed to use specifically on a Freightliner truck. The pipe connects to the turbocharger at one end and to the exhaust After-Treatment System (ATS), a type of catalytic converter at the other end. The pipe is constructed of aluminized steel. It is approximately 1 meter in length with a thickness of 1.65 millimeters (mm) and an outer diameter of 89 (mm). Each end of the pipe is slightly flared to make connection to the turbocharger and ATS. The tube is mostly covered with a thermal ceramic “super wool”. Insulating blanket, comprised of silica, calcium oxide, magnesium oxide and trace amounts of alumina, which serves to protect the engine and other components from the extreme heat of the exhaust gas, and also to retain heat to aid in the combustion of the exhaust gas as it enters the ATS.
As noted in your request, the Exhaust Bellows (Part # A04-25021) is a pipe assembly, specifically designed for use in Freightliner truck exhaust systems. It is comprised of a 4 inch diameter flexible stainless steel pipe and is available in lengths of 12, 16 or 18 inches. It is fitted with a torque clamp on each end, and has an inner liner made of stainless steel. The Exhaust Bellows is installed between the turbocharger and the exhaust After-Treatment System (ATS), which is a type of catalytic converter. It connects at one end to a turbocharger outlet pipe and at the other end to an ATS inlet pipe. The Exhaust Bellows performs the functions of (1) vibration dampening, (2) noise reduction, (3) compensating for misalignment between exhaust pipes that is caused by heat expansion within the exhaust system, and (4) providing flexibility to accommodate movement within the exhaust system in order to prevent the transfer of forces that might damage more sensitive components.
According to the information provided in your request, the Exhaust Elbow Pipe (Part # 04-27790) is a bent to shape pipe designed specifically for use in the exhaust system of a Freightliner truck. It forms part of the exhaust piping that carries exhaust from the exhaust ATS to the atmosphere. It is made of aluminized stainless steel. The pipe is approximately 1 meter in overall length, with a thickness of 1.65 (mm) and an outside diameter of approximately 102 (mm). The pipe is bent at a ninety degree angle near the midpoint of its length and is slightly tapered at one end. It does not contain any fittings as imported.
The applicable subheading for the Exhaust Bellows (Part # A04-25021) will be 8708.99.8180, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other: Other.” The general rate of duty will be 2.5%.
The applicable subheading for the Turbo Outlet Pipe (Part # A04-26053) and the Exhaust Elbow Pipe (Part # 04-27790) will be 8708.92.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Mufflers and exhaust pipes; parts thereof: Mufflers and exhaust pipes: For other vehicles.” The general rate of duty will be 2.5%. 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, please contact National Import Specialist Matthew Sullivan at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division