CLA-2-73:OT:RR:NC:N1:113
Ms. Susan Kohn Ross
Mitchell Silberberg & Knupp
11377 West Olympic Boulevard
Los Angeles, CA 90064-1683
RE: The tariff classification of marine hatches and components from China
Dear Ms. Ross:
In your letter dated November 2, 2017, on behalf of Universal Motion Components, Co., Inc. (UMC), you requested a tariff classification ruling on marine hatches and components. Photographs, engineering drawings and specifications for the marine hatches and components were submitted for our review.
The articles for which you are requesting a ruling are identified as UMC’s aluminum deck hatches, hatch cover assemblies and deck rings, and steel hatch covers and deck rings. You stated in your letter that “The articles covered by this ruling request are permanently welded to the decks of barges, workboats, commercial fishing boats and other vessels, and provide access to storage tanks and cargo holds via their water-tight covers. Each will be imported as a finished product, ready for installation.”
The first product under consideration is an 8 inch round aluminum hatch, SKU: BFHRTH8A/A (08863-110A). The second product is a 15 inch x 24 inch aluminum hatch cover, SKU: BFHO15X24A (08861-102A). The hatch cover is considered a replacement part since a buyer orders it only if a hatch is already in place. The third product is a 15 inch x 24 inch aluminum deck ring, SKU: 15X24-RING-AL (08861-203A). The deck ring is the outer portion of the hatch assembly and is considered a replacement part. The fourth product is a 20 inch cast steel hatch cover, SKU: BFHR20S (08861-192B). Hatch covers are categorized by UMC as replacement parts. The fifth product is a 20 inch cast steel deck ring, SKU: 20RND-RING-ST (08861-297A). The deck ring is categorized by UMC as a replacement part.
You indicated in your letter that a typical hatch includes a cover and a deck ring. The cover and the deck ring are components that are specifically designed for use in a particular deck hatch. The subject covers and deck rings will be used to replace worn out components. These articles are permanently welded to the deck of the vessel to which they are affixed.
The applicable subheading for the 8 inch round aluminum hatch , SKU: BFHRTH8A/A (08863-110A), the 15 inch x 24 inch aluminum hatch cover, SKU: BFHO15X24A (08861-102A), and the 15 inch x 24 inch aluminum deck ring, SKU: 15X24-RING-AL (08861-203A), will be 7616.99.5190, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of aluminum, other…other. The general rate of duty will be 2.5 percent ad valorem.
The applicable subheading for the 20 inch cast steel hatch cover, SKU: BFHR20S (08861-192B), and the 20 inch cast steel deck ring, SKU: 20RND-RING-ST (08861-297A), will be 7326.90.8688, HTSUS, which provides for other articles of iron or steel, other, other…other. The general rate of duty will be 2.9 percent 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 https://hts.usitc.gov/current.
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 Ann Taub at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division