Ned Marshak
Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP
399 Park Avenue, 25th Floor
New York, New York 10022-4877

RE: The tariff classification of light rail vehicle shell bodies from Italy

Dear Mr. Marshak,

In your letter dated December 23, 2014, you requested a tariff classification ruling on behalf of Ansaldobreda S.p.A. (Ansaldobreda) of Naples, Italy. The items under consideration have been identified as Light Rail Vehicles (LRV) Semi-Finished Half Body Shells.

In your request, you stated that the LRV Semi-Finished Car Body Shells will be imported from Italy for use in the Honolulu Authority for Rapid Transportation (HART). In their condition as imported, each of the car shells consists solely of a steel frame assembled with U.S. origin floors and insulation in Italy. None of the components necessary for the LRV to operate are included on the LRV shells as imported. Once imported, they will be assembled with trucks and a wide variety of other subassemblies and components parts into finished, self-propelled LRVs. The subassemblies and components include, but are not limited to windshields and windows, passenger seats, truck frames, complete axles/axle wheels, bolsters brakes systems and other structural elements. Each finished LRV will consist of (2) two end (E1 and E2) and (2) two middle (M1 and M2) cars which, in operation, are connected together.

You illustrated in your letter that the value of components added in the United States, including insurance, bond, project management fees and transportation costs is approximately 53% greater than the imported value of the car shells.

The applicable subheading for the Light Rail Vehicles (LRV) Semi-Finished Half Body Shells will be 8607.99.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts of railway or tramway locomotives or rolling stock: Other: Other: Other.” The general rate of duty will be 3.1%. 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 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, please contact National Import Specialist Matthew Sullivan at


Gwenn Klein Kirschner
National Commodity Specialist Division