CLA-2-84:OT:RR:NC:1:102
Mr. Sebastian Eich
Aventis Atlantic partners LLC
245 N. Highland Ave NE
Atlanta GA, 30307
RE: The tariff classification of Parts used in the 3/2 Solenoid Valve NV116 from Germany.
Dear Mr. Eich:
In your letter dated April 03, 2014 you requested a tariff classification.
The merchandise under consideration is described as parts of the 3/2 Solenoid Valve NV116: “Actuator Pin” Part Number 16414 002, “Cu Enameled Wire” Part Number 16434 001, “Pin (coiled on plastic reel)” Part Number 16410 001, and “Conductor sleeve” 16433 001.
The Actuator Pin, Part Number 16414 002 is constructed of Brass and is manufactured though a turning process. The item measures approximately 7.9 mm x 28.43 mm and weighs 1.6 grams. It is said the Actuator Pin is moved down by the armature with magnetic force or up by the compression spring in such a manner that electrical connections can be opened or closed.
The Pin, Part Number 16410 001is constructed of Cu alloy (Cu and Sn plated) and is manufactured through a stamping process. The item measures approximately 33 mm x rd.300 mm x rd.640 mm and weighs 0.41 grams. It is said; the Pin sits in the connector and is designed to connect with the pins in the mating connector.
You have suggested classifying part number 16414 002 and part number 16410 001 within heading 7415, HTSUS. This heading provides for nails, tacks, drawing pins, staples (other than those of heading 8305) and similar articles, of copper or of iron or steel with heads of copper, screws, bolts, nuts, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of copper. Classification of merchandise under the Harmonized Tariff Schedule of the United States is governed by the General Rules of Interpretation (GRIs) taken in order. GRI 1 provides that classification is determined first in accordance with the terms of the headings and any relative section and chapter notes. Part number 16414 002, described as an actuator pin, and part number 16410 001, described as a pin coiled on a plastic reel, are not ejusdem generis to the exemplars of heading 7414. Therefore, your suggested classification would be incorrect. The Actuator Pin, Part Number 16414 002 and the Pin, Part Number 16410 001 is part of a valve assembly that controls the flow of fluid within a fluid power transmission system. Valves for hydraulic power transmission systems are specifically provided for in subheading 8481.20 of the Harmonized Tariff Schedule of the United States (HTSUS).
The applicable subheading for the Actuator Pin, Part Number 16414 002 and the Pin, Part Number 16410 001 will be 8481.90.9040, HTSUS, which provides for other parts of the valves of subheading 8481.20. The rate of duty is free.
Your inquiry does not provide enough information for us to give a classification ruling on the Cu Enameled Wire, Part Number 16434 001. Your request for a classification ruling should include the answers to the following questions:
Provide a sample, and detailed literature explaining how the item functions.
How is the enameled wire being imported? Specifically, will the enameled wire be on spools or cut to length?
Your inquiry does not provide enough information for us to give a classification ruling on the Conductor sleeve” 16433 001. Your request for a classification ruling should include the answers to the following questions:
Provide a sample, and detailed literature explaining how the item functions.
How is the Conductor sleeve imported? Specifically, does the wire that was mentioned in your letter come already welded to the pin?
Explain fully what is meant by “Assists in the welding process when wire is welded to pin”. What is the method of operation?
Is the Conductor Sleeve electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits (for example, switches, relay, fusses, plugs, sockets, connectors, etc.)? Please provide a list of all that apply.
When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.
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 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,
Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division