CLA-2-84:OT:RR:NC:N1:103
Maureen E. Thorson
Wiley Rein LLP
2050 M Street NW
Washington, DC 20036
RE: The tariff classification of basic bucket and pallet fork attachments from the Czech Republic
Dear Ms. Thorson:
In your letter dated May 16, 2022, you requested a tariff classification ruling on behalf of your client, First Green Industries a.s.
The first item under consideration is a basic bucket attachment, part number 85188, for the Elise 900, which you refer to as a "skid loader." The bucket attachment has a capacity of 0.46 cubic meters, a width of 1880 millimeters, and is made of steel. The bucket may or may not include teeth, weighing 235 kilograms (without teeth) or 252 kilograms (with teeth). Each bucket attaches to the arms of the Elise 900, which angle, raise, or lower the bucket, allowing the skid loader to scoop and shovel items.
The second item under consideration is a basic bucket attachment, part number 85080, for the MiniZ, which you refer to as a "skid loader." The bucket attachment has a capacity of 0.09 cubic meters, a width of 800 millimeters, and is made of steel. The bucket may or may not include teeth, weighing 50 kilograms (without teeth) or 57 kilograms (with teeth). Each bucket attaches to the arms of the MiniZ, which angle, raise, or lower the bucket, allowing the skid loader to scoop and shovel items.
The third item under consideration is a pallet fork attachment, part number 86120, for the Elise 900 skid loader. The pallet fork attachment consists of a carriage and fork assembly made of steel that weighs 192 kilograms. Each attachment has a load capacity of 2,000 kilograms and includes forks that are 1200 millimeters in length. Each pallet fork attachment is mounted to the front arms of the Elise 900 where it is raised and lowered, allowing the Elise 900 to load and move materials.
The fourth item under consideration is a pallet fork attachment, part number 26080, for the MiniZ skid loader. Each pallet fork attachment consists of a carriage and fork assembly made of steel that weighs 92 kilograms. Each attachment has a load capacity of 300 kilograms and includes forks that are 800 millimeters in length. Each pallet fork attachment is mounted to the front arms of the MiniZ where it is raised and lowered, allowing the MiniZ to load and move materials.
You suggest the basic bucket attachments and pallet fork attachments are classified under subheading 8431.20.0000, Harmonized Tariff Schedule of the United States (“HTSUS”). We agree. In NY ruling N315094, dated October 27, 2020, U.S. Customs and Border Protection determined both the Elise 900 and MiniZ loaders were classified in heading 8427, HTSUS. Both the bucket attachments and pallet fork attachments are designed solely for use with the Elise 900 or MiniZ loaders and are classified as parts thereof.
The applicable subheading for the basic bucket attachments, part numbers 85188 and 85080, and pallet fork attachments, part numbers 86120 and 26080, will be 8431.20.0000, HTSUS, which provides for “Parts suitable for use solely or principally with the machinery of headings 8425 to 8430: Of machinery of heading 8427.” 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 the 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 Paul Huang at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division