CLA-2-84:OT:RR:NC:N1:102
William Jeeves
Proactive Analytics Limited
5 London Road, Rainham
Gillingham ME8 7RG
United Kingdom
RE: The tariff classification of a valve arrangement from the United Kingdom
Dear Mr. Jeeves:
In your letter dated March 17, 2025, you requested a tariff classification ruling. Descriptive information was
provided in the submission.
The ExiInta, which is referred to as a block and bleed valve arrangement, is used in process, utility and
service lines of sanitary and hygienic separation installations. The ExiInta valve arrangement consists of a
steel housing that encases basic electronic components, solenoid valves that control the flow of waste, and
pressure sensors that send information that contribute to the operation of the solenoid valves. The valve
arrangement is electronically controlled by the ExiFlo product, which was previously ruled on in New York
ruling N344160, dated December 9, 2024.
In your letter, you suggest the ExiInta is classified within subheading 9026.80.2000, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for “Instruments and apparatus for measuring or
checking the flow, level, pressure or other variables of liquids or gases (for example, flow meters, level
gauges, manometers, heat meters), excluding instruments and apparatus of heading 9014, 9015, 9028 or
9032; parts and accessories thereof: Other instruments and apparatus: Electrical.” We disagree. The primary
function of the ExiInta is to protect the ExiFlo from temperature and pressure variations, as well as to allow
the user to bleed the connected line or stop the flow of liquid altogether for maintenance. The ExiInta, which
is a separate component in the ExiFlo system, is more akin to a valve being told to open and close based on
the ExiFlo’s instructions. It is not a checking or measuring device. Therefore, heading 9026, HTSUS, is
excluded from consideration.
As the ExiInta functions as a valve system, it is more appropriately classified within heading 8481, which
provides for valves. Accordingly, the applicable subheading for the ExiInta will be 8481.80.9005, HTSUS,
which provides for Taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like,
including pressure-reducing valves and thermostatically controlled valves; parts thereof: Other appliances:
Other: Solenoid valves. The general rate of duty will be 2 percent ad valorem.
Effective April 5, 2025, Executive Orders implemented ?Reciprocal Tariffs.? All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs.?Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to
subheading 8481.80.9005, HTSUS, listed above.
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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
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 Sandra Martinez at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division