CLA-2-84:OT:RR:NC:N2:206
William F. Jansen
International Supply Chain Specialist
Noatum Logistics
8550 W Bryn Mawr Ave
Chicago, IL 60631
RE: The tariff classification of a roller blank from Germany.
Dear Mr. Jansen:
In your letter dated June 16, 2020, you requested a tariff classification ruling on behalf of your client, GT Technologies.
The item under consideration is a Roller Blank, which is used to produce a rocker arm assembly. The purpose of a rocker arm assembly is to transfer energy from a cam lobe to open a poppet valve used for intake/exhaust in a diesel engine. As the cam lobe is raised, this causes the rocker to press down on a valve stem, which causes the valve to open. In this mechanism, a roller contacts the cam lobe and transfers energy to the rocker. Once energy is transferred to the rocker, the valve stem is lowered causing to open or close the valve. As imported, the roller forms an integral part of the rocker arm, which is designed for sole use within a rocker arm assembly.
In your letter, you suggest the roller blank may be classified in heading 8482, Harmonized Tariff Schedule of the United States (HTSUS), which provides for ball or roller bearings, and parts thereof. However, the roller assembly is not constructed as a ball or roller type bearing that reduces friction. It is a rolling mechanism that actuates a valve. As such, the roller blank is excluded from consideration of heading 8482, HTSUS.
You also suggest classifying the roller blank in subheading 8409.91.5085, HTSUS, which provides for parts of spark ignited engines. However, you state that the roller blank is used in diesel engines of vehicles designed to transport less than 10 people. As a result, classification of the roller blank in subheading 8409.91.5085, HTSUS, is also precluded.
The applicable subheading for the Roller Blank will be 8409.99.9190, HTSUS, which provides for “Parts suitable for use solely or principally with the engines of heading 8407 or 8408: Other: Other: Other: For vehicles of subheading 8701.20, or heading 8702, 8703 or 8704: Other.” The general 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 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, please contact National Import Specialist Liana Alvarez at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division