CLA-2-39:OT:RR:NC:N2:421

Solomon Sarang
Central Purchasing LLC DBA Harbor Frieight Tools
26541 Agoura Road
Calabasas, CA 91302

RE: The tariff classification of air hose reels from China

Dear Mr. Sarang:

In your letter dated January, 4, 2016, you requested a tariff classification ruling.

The three products at issue are referred to as air hose reels, each comprising a hose and a reel that are imported and sold together. The air hose reels are identified by individual SKU numbers, and are intended for use with pneumatic hand tools.

SKU # 69232 (Air Hose Reel) consists of a 3/8 inch by 50 foot air hose and a reel. The reel is made of steel and includes a manual reel mechanism, while the hose is constructed of rubber reinforced with braided polyester and features male brass fittings at both ends.

SKU # 69265 (Retractable Hose Reel) consists of a 3/8 inch by 50 foot air hose and a reel. The reel is made of steel and includes a spring-loaded auto-rewind reel mechanism, while the hose is constructed of rubber reinforced with braided polyester and features male brass fittings at both ends.

SKU # 69267 (Enclosed Retractable Air Hose Reel) consists of a 3/8 inch by 50 foot air hose and a reel. The reel is made of plastic and includes a spring-loaded auto-rewind reel mechanism, while the hose is constructed of polyvinyl chloride (PVC) plastic reinforced with braided polyester and features male brass fittings at both ends.

The hoses serve to deliver pressurized air from an air compressor to pneumatic hand tools while the reels, which can be mounted to a wall or ceiling, provide storage for the hose. Like the hose and reel combinations ruled upon in New York Ruling Letters I89054 and N217149, dated December 23, 2002 and June 7, 2012 respectively, the essential character of the air hose reels at issue is imparted by the hoses.

The applicable subheading for SKU #s 69232 and 69265 will be 4009.32.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Tubes, pipes and hoses, of vulcanized rubber other than hard rubber…: Reinforced or otherwise combined only with textile materials: With fittings, Other. The rate of duty will be 2.5 % ad valorem.

The applicable subheading for SKU # 69267 will be 3917.39.0020, HTSUS, which provides for Tubes, pipes and hoses and fittings therefor (for example, joints, elbows, flanges), of plastics: Other tubes pipes and hoses: Other: Other: Of polyvinyl chloride. The rate of duty will be 3.1% 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,

Deborah C. Marinucci
Acting Director
National Commodity Specialist Division