CLA-2-84:OT:RR:NC:N1:104
Mr. Jason Carey
Aspire Group NA Ltd
498 Markland Street #1
Markham, Ontario L6C1Z6
Canada
RE: The tariff classification of an ENDURO Caravan Maneuvering System from China
Dear Mr. Carey:
In your letter dated May 26, 2015 you requested a tariff classification ruling.
The ENDURO Caravan Maneuvering System is sold as an aftermarket add-on for campers. The system allows the user to maneuver the camper by remote control in order to park the camper in a particular location. It also provides for a finer positioning of the camper rather than being towed by a vehicle. The maneuvering system consists of a battery operated motor, precise gear drives, aluminum drive rollers and a hydraulic arm to engage or disengage the drive rollers to the camper tires. One unit is needed for each wheel on the camper. The units are permanently installed to the chassis of the camper where the drive rollers have sufficient room to engage the tires prior to moving and to disengage the tires once it has been positioned. When the arm pushes the drive rollers against the tires, the rollers will either engage or disengage the tire. This permits the motor to roll the tire either forward or backwards. A remote control controls the movement and works with each unit attached to the camper in order to achieve the desired positioning.
There are four models that have minor differences in construction and appearance and vary by the weight of the camper. Models ES305 and ES304 are for campers that weigh up to 3000 kgs. The difference is that Model ES305 is a fully automatic system while the Model ES304 is a semiautomatic system containing a manual crank to engage the drive rollers instead of an automatic arm. Models EM303A and EM303 are for campers that weigh up to 2500kgs. Model EM303A is a fully automatic system while Model EM303 is a semiautomatic model that contains a manual crank to engage the drive rollers instead of an automatic arm.
The applicable subheading for the ENDURO Caravan Maneuvering Systems, Models ES304, ES305, EM303A and EM303, will be 8479.89.9899 Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter, parts thereof: Other machines and mechanical appliances: Other: Other: Other”. The rate of duty will be 2.5% ad valorem.
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 Patricia O’Donnell at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division