CLA-2-84:OT:RR:NC:N1:102
Matthew J. Basile
Star Asia Customs, Trade and Security, Inc.
208 Church St.
Decatur, Georgia 30030
Re: The tariff classification of three shafts for lawnmowers from China
Dear Mr. Basile,
In your electronic submission dated August 26, 2020, you requested a tariff classification ruling for three shafts for lawnmowers on behalf of your client, Standby Screw Machine Products, Inc.
The items in question are shafts, part numbers 51062, 1A6460-34150, and 187K00-34131. These shafts are constructed of carbon steel and transmit rotary power once assembled to the lawnmower hydrostatic transaxle, which is not a part of this request.
Part number 51062 is referred to as a Lawnmower Input Shaft. The shaft is machined to shape, splined on both ends and threaded to accept a fan pulley, which is a belt driven input connection between the mower engine and the hydrostatic transaxle. The input shaft transfers power generated from the hydrostatic transaxle.
Part number 1A6460-34150 is referred to as the Riding Lawnmower Hydrostatic Axle Shaft. On one end, the axle shaft is splined to affix to the hydrostatic transaxle. The opposite end of the axle shaft is machined with a keyway that allows it to fasten the drive wheels. The axle shaft transfers power from the hydrostatic transaxle to the drive wheels, creating motion for the lawn mower.
Part number 187K00-34131 is referred to as the Zero Turn Lawnmower Hydrostatic Axle Shaft. The axle shaft is machined to shape, splined on both ends and threaded on one end. The shaft affixes to the hydrostatic transaxle and a four lug wheel hub to which the drive wheels are mounted. The axle shaft transfers power from the hydrostatic transaxle to the drive wheels, creating motion for the lawn mower.
In your letter you suggest that the subject shafts are classified within subheading 8483.40.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: Transmission shafts (including camshafts and crankshafts) and cranks; bearing housings, housed bearings and plainshaft bearings; gears and gearing; ball or roller screws; gearboxes and other speed changers, including torque converters; flywheels and pulleys, including pulleyblocks; clutches and shaft couplings (including universal joints); parts thereof; Gears and gearing, other than toothed wheels, chain sprockets and other transmission elements entered separately; Gears and gearing, other than toothed wheels, chain sprockets and other transmission elements entered separately; ball or rollerscrews; gearboxes and other speedchangers, including torque converters; Gears and gearing, other than toothed wheels, chain sprockets and other transmission elements entered separately. While we agree the shafts are classified within heading 8483; we disagree at the subheading level.
Explanatory Note (A) to Heading 8483, in pertinence, explains that transmission shafts (including Cam Shafts and Crank Shafts) transmit a rotary motive power. Explanatory Note (A) to Heading 8483 goes on to list various types of shafts, including: main shafts, counter shafts, articulated shafts, flexible shafts, cranks and crank shafts, and cam shafts and eccentric shafts, as shafts provided for in this heading. Here, the items in question are shafts that transmit rotary power received from the hydrostatic transaxle, which is powered by the lawn mower engine. Therefore, the shafts in question are classified within subheading 8483.10.
You also request consideration under subheading 8483.90.8080, HTSUS, which provides for: Transmission shafts (including camshafts and crankshafts) and cranks; bearing housings, housed bearings and plainshaft bearings; gears and gearing; ball or roller screws; gearboxes and other speed changers, including torque converters; flywheels and pulleys, including pulleyblocks; clutches and shaft couplings (including universal joints); parts thereof; Toothed wheels, chain sprockets and other transmission elements presented separately; parts: Other: Other: Other. However, as mentioned above, shafts that transmit rotary power are specifically provided for under subheading 8483.10.
As such, the applicable subheading for the Hydrostatic Transaxle Lawnmower Input Shaft, Part Number 51062, Riding Lawnmower Hydrostatic Axle Shaft, Part Number 1A6460-34150, and the Zero Turn Lawnmower Hydrostatic Axle Shaft, Part Number 187K00-34131, will be 8483.10.5000 HTSUS, which provides for Transmission shafts (including camshafts and crankshafts) and cranks; bearing housings, housed bearings and plainshaft bearings; gears and gearing; ball or roller screws; gearboxes and other speed changers, including torque converters; flywheels and pulleys, including pulleyblocks; clutches and shaft couplings (including universal joints); parts thereof; Transmission shafts (including camshafts and crankshafts) and cranks, Other transmission shafts and cranks. The general rate of duty is Free.
Products of China classified under subheading 8483.10.5000, HTSUS, unless specifically excluded, are subject to the additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8483.10.5000 HTSUS, listed above. The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading.
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 ยง 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 Sandra Martinez at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division