CLA-2-88:OT:RR:NC:N2:101
Catherine L. Spencer, Compliance
Freight Expediters
6920 Engle Road, Suite II
Middleburg Heights, OH 44130
RE: The tariff classification of drone propellers and propeller guards from China
Dear Ms. Spencer:
In your letter dated August 22, 2017, you requested a tariff classification ruling on behalf of your client, International Products Sourcing Group, Hilliard, Ohio.
The items under consideration have been identified as the DJI Mavic Propeller Quick Release Folding Propellers (CP.PT.000578), and Mavic Propeller Guard.
The first item, the DJI Mavic Propeller Quick Release Folding Propellers, are plastic drone propellers which, you state, are packaged two per box. Additionally, you state that these propellers are easy to fold, have powerful thrust, and are well balanced with a push type design for easy mounting. The diameter cross thread is 8.3 x 3.0 inch. These are compatible with the Mavic Pro and the Mavic Propeller Guard.
In your request you state that you believe that the proper classification will be 8803.10.0060. This office concurs.
The applicable subheading for the DJI Mavic Propeller Quick Release Folding Propellers (CP.PT.000578) will be 8803.10.0060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts of goods of heading 8801 or 8802: Propellers and rotors and parts thereof: Other”. The rate of duty will be Free.
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 https://hts.usitc.gov/current.
The second item, the Mavic Propeller Guard, is used to cover and protect the Mavic Pro drone propellers and to ensure flight safety and protection from spinning propellers. The propeller guards are made of plastic and designed to be mounted directly on the propellers to ensure a safe and long flight. They are lightweight, weighing only 40.25 grams and have a radius of 125 mm.
Your inquiry does not provide enough information for us to give a classification ruling on the Mavic Propeller Guard. Your request for a classification ruling should include answers to the following questions:
Are there any instances when these guards are included / packaged with the Mavic Pro drone?
Does DJI include similar guards or have ones built into any of their other drone models?
How are these guards marketed?
Does DJI recommend the use of these guards for the Mavic Pro? If so, is it more for the safety of the operator and those around or to protect the drone from damage?
If these guards were not installed, what would happen if a propeller came in contact with an object? Would the drone most likely crash or would it still be able to fly, of course dependent how hard and what it hit?
When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.
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 Matthew Sulllivan at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division