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 upper housings, part numbers 11787 and 11786, and lower housings, part numbers 11915 and 11914. Part numbers 11787 and 11915 are assembled with other parts to form the Fairchild Model 90 (Low Pressure) Selecting Relay. Part numbers 11786 and 11914 are assembled with other parts to form the Fairchild Model 91 (High Pressure) Selecting Relay. The upper and lower housings function as valve bodies for the selecting relays, which are pneumatic valves.

The applicable subheading for the lower and uppers housings, part numbers 11787, 11786, 11915, 11914, 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 subheading 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 subheading 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

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