CLA-2-84:OT:RR:NC:N1:102
Robert D. DeCamp
Sandler, Travis & Rosenberg, P.A.
551 Fifth Avenue, Suite 1100
New York, New York 10176
RE: The tariff classification of pneumatic valve parts from China
Dear Mr. DeCamp:
In your letter dated August 18, 2020, you requested a tariff classification ruling on behalf of your client, A&C Trade Consultants Inc.
The items at issue are bonnets, part numbers 19965 and 20028, valve bodies, part numbers 19963 and 21837, and dripwells, part numbers 19967 and 21838. The bonnets, valve bodies, and dripwells are of aluminum material and are used in the Model 63 Pneumatic Filter Regulator, which is a pneumatic regulator valve.
The bonnets are described as valve enclosures and are designed to mount onto the diaphragm assembly of the valve.
The valve bodies are structural components of a valve that feature an inlet and an outlet.
Dripwells are designed to collect and drain water.
The applicable subheading for the bonnets, part numbers 19965 and 20028, will be 8481.90.9040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Taps, cocks, valves and similar appliances, for pipes, boilershells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Parts: Other: Of valves of subheading 8481.20: Other. The rate of duty will be Free.
The applicable subheading for the valve bodies, part numbers 19963 and 21837, will be 8481.90.9020, HTSUS, which provides for Taps, cocks, valves and similar appliances, for pipes, boilershells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Parts: Other: Of valves of subheading 8481.20: Valve body. The rate of duty will be Free.
Pursuant to U.S. Note 20 Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 8481.90.9040 and 8481.90.9020, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheadings 8481.90.9040 and 8481.90.9020, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading.
For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at:
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actionshttps://www.cbp.gov/trade/remedies/301-certain-products-china
Your inquiry does not provide enough information for us to give a classification ruling on the dripwells, part numbers 19967 and 21838. Explain why the Model 63 Pneumatic Filter Regulator cannot operate without the presence of the dripwells. Describe how the dripwells function in regards to the valve. Do the dripwells have any mechanical features? If so, please identify the features by name and explain how they function.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. ยง 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 Sandra Martinez at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division