CLA-2-73:OT:RR:NC:N1:113
Mr. Marc Torrence
Bridgestone Americas Tire Operations
535 Marriott Drive
Nashville, TN 37214
RE: The tariff classification of pistons and clamp rings from China, Italy and Germany
Dear Mr. Torrence:
In your letter dated July 19, 2017, you requested a tariff classification ruling. Pictures of two aluminum pistons, one steel piston and one steel clamp ring, and a document showing a breakdown of the components of a typical air spring including the piston and clamp ring were submitted with your ruling request for our review.
The articles for which you are requesting a ruling are three different components of an air spring vibration reduction product including steel pistons, aluminum pistons and steel clamp rings. The steel pistons are produced in Italy, the aluminum pistons in China and the steel clamp rings are made in Germany. You stated in your letter that the “Air springs are used for vibration isolation reduction and shock absorbing across numerous industries, including: (1) passenger cars, heavy trucks, trailers, buses and motorcycles (2) rail and (3) industrial vehicles and machinery.” You indicated that the end use (specific industry) for the pistons and clamp rings is not known until the subject article is placed in inventory after importation and then picked for assembly into the air spring. In their condition as imported, the pistons and clamp rings under consideration are finished goods and no further manufacturing is performed on them. As entered into the United States, the pistons and clamp rings will be introduced onto the assembly line and incorporated into an air spring.
In the document showing the components of Sleeve Style Springs, the piston is described as the lower end of the assembly that the rubber rolls over and it provides the lower mounting hardware for the assembly. The clamp rings are described as metal rings used to permanently attach the bellows to the clamp plate and piston. The document presenting the components of the Firestone Airide Springs indicates that the piston is “The lower section of the 1T and 1X style of airspring made from aluminum, steel or fiber reinforced plastic. It provides lower mounting arrangement for the airspring in the form of tapped holes or studs.”
The applicable subheading for the steel pistons and steel clamp rings will be 7326.90.8688, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel, other, other, other, other, other. The general rate of duty will be 2.9 percent ad valorem.
The applicable subheading for the aluminum pistons will be 7616.99.5190, HTSUS, which provides for other articles of aluminum, other…other. The general rate of duty will be 2.5 percent 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 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 Ann Taub at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division