CLA-2-84:OT:RR:NC:N1:102
Robert D. DeCamp
Sandler, Travis & Rosenberg, P.A.
551 Fifth Avenue, Suite 1100
New York, New York 10176
RE: The tariff classification of pneumatic valve parts from China
Dear Mr. DeCamp:
In your letter dated August 18, 2020, you requested a tariff classification ruling on behalf of your client, A&C Trade Consultants Inc.
The items at issue are a bonnet, part number 21153, a spacer ring, part number 21155, a piston, part number 21119, and a valve body, part number 21157. The bonnet, spacer ring, piston, and and valve body are of aluminum material and are used in the Model 4800A Pneumatic Volume Booster, which is a type of pneumatic regulator valve.
The bonnet mounts onto the diaphragm assembly of a valve and functions as an enclosure for a valve.
The valve body is a structural component of a valve that features an inlet, and an outlet. The valve body is said to be precisely machined to accommodate other valve components.
The spacer ring is designed to give the pneumatic valve extra room.
The piston sets various valve parts.
The applicable subheading for the bonnet, part number 21153, will be 8481.90.9040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Taps, cocks, valves and similar appliances, for pipes, boilershells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Parts: Other: Of valves of subheading 8481.20: Other. The rate of duty will be Free.
The applicable subheading for the valve body, part number 21157, will be 8481.90.9020, HTSUS, which provides for Taps, cocks, valves and similar appliances, for pipes, boilershells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Parts: Other: Of valves of subheading 8481.20: Valve body. The rate of duty will be Free.
Pursuant to U.S. Note 20 Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 8481.90.9040, and 8481.90.9020, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheadings 8481.90.9040, and 8481.90.9020, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading.
For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at:
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actionshttps://www.cbp.gov/trade/remedies/301-certain-products-china
Your inquiry does not provide enough information for us to give a classification ruling on the spacer ring, part number 21155, and the piston, part number 21119. Please provide additional information that describes the physical features of the spacer and the piston. Submit pictures or photographs that illustrate the spacer and piston from all sides and angles. Explain why the Model 4800A Pneumatic Volume Booster cannot operate without the presence of the spacer and the piston. Clearly describe the physical features that prevent the spacer and the piston from being used in other applications. Does the piston complete the valve’s actuator?
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 Sandra Martinez at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division