CLA-2-94:OT:RR:NC:N4:433
David T. Adams
Recaro Aircraft Seating Americas, LLC.
2275 Eagle Parkway
Forth Worth, TX 76177
RE: The tariff classification of an aircraft seat component from Germany.
Dear Mr. Adams:
In your letter dated September 16, 2019, you requested a tariff classification ruling. Illustrative literature and a product description were provided for review.
Part number 130-00-813-25+00 described as the “Cover Sheet Table Side” is a component of the frame assembly of a Recaro aircraft passenger seat. Installed in the armrest structure of a seat, the “Cover Sheet Table Side” provides structural support to the inner structure of the armrest assembly. You indicate the item is made of 6082T6 aluminum, built to a Recaro design specification, and is for aircraft seat installation only.
In consideration of the “Cover Sheet Table Side” digital photos and the Recaro build specification sheet provided, you are inclined to classify the item in subheading 9401.90.5081, Harmonized Tariff Schedule of the United States, (HTSUS).
The Explanatory Notes (ENs) to the HTSUS constitute the official interpretation of the tariff at the international level. The ENs to Chapter 94 of the HTSUS, “Parts,” state: “This Chapter only covers parts, whether or not in the rough, of goods of heading 9401 to 9403 and 9405, when identifiable by their shape or other specific features as parts designed solely or principally for an article of those headings. They are classified in this Chapter when not more specifically covered elsewhere.” See Headquarters ruling H265042 dated July 18, 2016.
This office is of the opinion that part number 130-00-813-25+00 is a dedicated part of a Recaro aircraft seat, and is not more specifically provided for elsewhere in the tariff schedule.
The applicable subheading for the subject merchandise will be 9401.90.50.81, HTSUS, which provides for “Seats (other than those of heading 9402), whether or not convertible into beds, and 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 the 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 Dharmendra Lilia at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division