CLA-2-1:OT:RR:NC:N1:104
Kristine Cackett
Hottinger Bruel & Kjear Inc
19 Bartlett Street
Marlborough, MA 01752
RE: The tariff classification of a header expander and slip table assemblies from the United Kingdom
Dear Ms. Cackett:
In your letter dated March 6, 2025, you requested a tariff classification ruling.
The two items at issue are specially designed fixtures for use with the company’s LDS Vibration Shaker
Systems which provide a controlled, simulated vibration environment for quality and reliability testing of
components and assemblies (payloads). The shakers are used in a wide variety of industries including
aerospace, military, automotive, electronics, manufacturing, and avionics.
The first item is a head expander, which consists of a flat top surface of magnesium alloy with a base for
attachment to the shaker machine’s armature. The flat surface includes holes for screwing down and securing
payloads. The head expander increases the capability of shaker systems by expanding the mounting surface,
allowing larger payloads. The head expander can be used with or without a guidance system which contains
mechanical guide bearings, micro-switches, and associated wiring. It will be imported with fasteners and
fitting tools for attaching payloads.
The second item is a slip table assembly, available in two configurations (LPT and HBT series). These are
test platforms used with the shakers to enable the machine to excite payloads in a single-axis (horizontal) or
three-axis testing configuration when testing very large or complex loads. The slip tables consist of a
magnesium slip plate (with attachment holes) sitting atop a granite block, with a lubricating film in between,
housed within a frame. For the LPT series, the slip plates use oil-fed bearings to guide the slip plates,
whereas the HBT series uses hydrostatic load-carrying bearings, suitable for heavier payloads and three-axis
testing. The slip tables can be used as either stand-alone tables or mounted together with a shaker machine on
a common metal base.
While the shaker machines are capable of functioning without the head expander or the slip tables, both items
are designed solely for use with the shaker machines and serve no other function or purpose apart from being
shaker machine fixtures.
In your submission, you query whether the two items can be classified as parts of shaker systems under
subheading 9024.90.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for
“Machines and appliances for testing the hardness, strength, compressibility, elasticity or other mechanical
properties of materials (for example, metals, wood, textiles, paper, plastics), and parts and accessories
thereof: Parts and accessories: Other.” The shaker system does not contain any components that would
provide a measuring function, notably for testing the hardness, strength, compressibility, or elasticity. The
system’s purpose is to simply excite (shake) the payload. Then, additional measuring devices may be used to
provide results, such as the accelerometers mentioned in your letter. The measuring devices would be
separately classifiable and perform a different function than the imported shaker. Accordingly, heading 9024,
HTSUS, would be excluded from consideration.
The applicable subheading for the head expander and slip table assemblies will be 8479.90.9596, HTSUS,
which provides for machines and mechanical appliances having individual functions, not specified or
included elsewhere in this chapter; parts thereof: Parts: Other: Other: Other. The general rate of duty will be
Free.
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 (including the United Kingdom) 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 subheadings 8479.90.9596, 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 the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. If 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 Arthur Purcell at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division