CLA-2-84:OT:RR:NC:N1:104
Ms. Julie Vair
Expeditors Tradewin, LLC
1015 Third Avenue
12th Floor
Seattle, WA 98104
RE: The tariff classification of Swivel Assemblies and Bumper Stop Assemblies from China
Dear Ms. Vair:
In your letter dated December 22, 2016 you requested a tariff classification ruling.
The importation consists of various swivel assemblies and bumper stop assemblies. Item number 600886, is a swivel assembly made of brass and copper material, item number 260057-1 is a swivel assembly made of aluminum, and item numbers 2-HR1004-3 and 602413 are bumper stop assemblies. The swivels and the bumper stop assemblies are designed for use in spring retractable and/or motorized industrial hose and electric cord reels. Samples submitted to this office will be returned.
The hose reels will not function without a swivel assembly. The swivel assembly allows the hose to fit properly on the spool of the reel and prevent restriction of flow due to proper alignment. The primary function of the swivel assembly is to provide bi-directional rotation, provide a low-friction connection in order to prevent the reel from rotating and pulling the hose back into the reel and provides leak-proof sealing capabilities. Depending on the pressure rating, each reel may use a different designed swivel assembly to fit a particular model of hose reel.
The bumper stop assembly provides a positive stop during retraction as an integral mechanical function of the reel. The bumper stops are sized specifically for Reelcraft reels. The Reelcraft hose, cord or cable reels will not function without a bumper stop assembly. Without the bumper stop, the hose or cord would retract all the way into the reel and lose the preset tension. The preset tension ensures proper torque in the drive spring in order to retract the hose, cord or cable.
According to supplemental information supplied to this office, item number 260057-1/swivel assembly incorporates aluminum components. The components are manufactured from aluminum material that was originally produced by an extrusion process. Once Reelcraft receives the aluminum material at its machining center, it is cut to length and followed up with lathe and milling machine work. This machining is done for the round stock and the hexagon stock.
In view of the above, item number 260057-1/swivel assembly which incorporates the aluminum components may be subject to antidumping duties or countervailing duties (AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade Administration of the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP). You can contact them at http://trade.gov/enforcement/ (click on “Contact Us”). For your information, you can view a list of current AD/CVD cases at the United States International Trade Commission website at http://www.usitc.gov (click on “Antidumping and Countervailing Duty” under “Popular Topics” at the top of the screen), and you can search AD/CVD deposit and liquidation messages using CBP’s AD/CVD Search tool at http://addcvd.cbp.gov/.
The applicable subheading for the Swivel Assemblies and the Bumper Stop Assemblies will be 8479.90.9496, 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: Parts: Other: Other: Other”. 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 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 Patricia O’Donnell at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division