CLA-2-76:OT:RR:NC:N2:421
Russell Bruce Thornburg
Charles Dorsch Ships Agent, Inc.
1981 Main Street
San Diego, CA 92113
RE: The tariff classification of jet ski parts from Taiwan
Dear Mr. Thornburg:
In your letter dated July 8, 2015, on behalf of Rick Roy Products, Inc., you requested a tariff classification ruling. Samples were provided, and will be returned to you.
The merchandise at issue in your submission consists of five products that are intended for use with jet ski watercraft. You identify the articles as Products B1 through B5. Product B1 has the part description of RRP Handlebar Extensions. The handlebar extensions are constructed of aluminum and stainless steel, and are designed to be attached to the ends of a jet ski’s existing handlebars. Per the information you provided, the aluminum predominates by weight over the stainless steel.
Product B2 is described as the RRP Steering System Protection Pad. The article consists of a stainless steel plate fully encased by PVC silicone, and measures approximately 3 inches by 4 inches. The pad is intended to be affixed to the base of a jet ski’s handlebars, to provide protection to a rider in the event of impact. The essential character of the Steering System Protection Pad is imparted by the PVC silicone.
Product B3 is referred to as the RRP Steering System Bearing and O-Ring Repair Kit. The kit contains two steel needle thrust bearings, four steel washers, and three nitrile rubber O-rings. The components of the kit are packaged together for retail sale, and are intended to be used to rebuild the steering bracket of a jet ski. The subject thrust bearings include needle rollers that measure 4.50 millimeters in length and 1.90 millimeters in diameter. In considering that the kit is designed to provide rotational movement and enable steering capability, it is the needle thrust bearings that impart the essential character to the kit in accordance with General Rule of Interpretation 3(b).
Product B4 is listed as the RRP Steering O-Ring Repair Kit. The kit contains three nitrile rubber O-rings that are intended to be used to replace used or worn O-rings in a jet ski’s steering system. Product B5 has the part description of RRP Yamaha 2 Hole Lowered Handpole Bracket. The product is a kit containing 15 components, including an aluminum two-hole bracket, an aluminum mounting bracket, two reinforced PVC hoses, and an assortment of bolts, washers, lock nuts, and clips. You indicate that all of the components are imported together as a kit and are used in the installation and mounting of air inlet hoses for a jet ski’s engine. The articles are packaged ready for retail sale, and would be considered a set for tariff purposes. The Yamaha 2 Hole Lowered Handpole Bracket is designed to secure the air inlet hoses that allow air to flow to the jet ski’s engine compartment. As such, the essential character of the article is imparted by the aluminum bracket.
The applicable subheading for the RRP Handlebar Extensions will be 7616.99.5090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other articles of aluminum: Other…Other. The rate of duty will be 2.5% ad valorem.
The applicable subheading for the RRP Steering System Protection Pad will be 3926.90.3000, HTSUS, which provides for Other articles of plastics…: Other: Parts for yachts or pleasure boats of heading 8903; parts of canoes, racing shells, pneumatic craft and pleasure boats which are not of a type designed to be principally used with motors or sails. The rate of duty will be 4.2% ad valorem.
In accordance with subheading note 2 to chapter 84, which states that Subheading 8482.40 applies only to bearings with cylindrical rollers of a uniform diameter not exceeding 5mm and having a length which is at least three times the diameter, the applicable subheading for the RRP Steering System Bearing and O-Ring Repair Kit will be 8482.50.0000, HTSUS, which provides for ball or roller bearings, and parts thereof; Other cylindrical roller bearings. The rate of duty will be 5.8 % ad valorem.
The applicable subheading for the RRP Steering O-Ring Repair Kit will be 4016.93.5010, HTSUS, which provides for Other articles of vulcanized rubber other than hard rubber: Other: Gaskets, washers and other seals: Other, O-rings. The rate of duty will be 2.5% ad valorem.
The applicable subheading for the RRP Yamaha 2 Hole Lowered Handpole Bracket 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 rate of duty will be 5.7% 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 Evan Conceicao at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division