CLA-2-85:OT:RR:NC:N2 207
Robert Scott
Curtiss-Wright Controls Integrated Sensing, Inc.
1100 W. Grove Pkwy., Ste. 102
Tempe, AZ 85283
RE: The tariff classification of parts of flight control surfaces from Canada and Mexico
Dear Mr. Scott:
In your letter dated March 25, 2026, you requested a tariff classification ruling.
There are five items at issue with this request, which are described as components for actuators and sensors
incorporated into aircrafts. Each item is identified by part numbers H466B MOTOR ASSEMBLY,
1015-400-215 HOUSING, RESOLVER, H569 Geared Resolver, 1064-400-094 Carrier Output, and 25565
Dual RVDT.
The H466B MOTOR ASSEMBLY is an electro-mechanical rotary actuator comprised of a DC brushless
motor with maximum power output of 300 Watts. The actuator is connected to aircraft flap linkages and it is
used to actuate the flight control surfaces or flaps of an aircraft. You state that this component is made in
Canada.
The 1015-400-215 HOUSING, RESOLVER is a metal housing used for mounting a resolver stator into an
electromechanical rotary actuator (H446B MOTOR ASSEMBLY). The housing is fully machined from
aluminum and the country of origin is Canada.
The H569 Geared Resolver is a position sensor referred to as a resolver or an inductive sensor. This sensor is
an electromagnetic transducer that can be used in a wide variety of position and velocity feedback
applications. It is used to sense the position of the flight control surface flaps by sending an electrical signal
to the aircraft’s flight computer identifying the flap position. You state that this component does not include a
motor or a valve and the country of origin is Mexico.
The 1064-400-094 Carrier Output is a mechanical part or component of the planetary gearhead used in the
H569 Geared Resolver. The gearhead’s planetary gears are mounted on the Carrier Output. This component
is fully machined out of stainless steel. The country of origin for this item is Canada.
The 25565 Dual RVDT is an assembly of two RVDTs assembled in-line and used to measure nosewheel
steering on a Boeing F/A-18 E/F aircraft. The RVDT is used in the power steering unit for the aircraft, which
provides an electrical output that is analyzed by the aircraft flight computer to determine the position of the
nosewheel of the aircraft. The country of origin for this item is Mexico.
In your submission, you suggest that H466B MOTOR ASSEMBLY is correctly classified under subheading
8501.31.4000, Harmonized Tariff Schedule of the United States (HTSUS), 1015-400-215 HOUSING,
RESOLVER is classified under subheading 8503.00.9520, HTSUS, H569 Geared Resolver and 25565 Dual
RVDT are classified under subheading 8543.70.4500, HTSUS. Additionally, you proposed the 1064-400-094
Carrier Output is correctly classified under subheading 8483.90.5080, HTSUS which provides for
“Transmission shafts (including camshafts and crankshafts) and cranks; bearing housings, housed bearings…
Parts of gearing, gear boxes and other speed changers: Other.” We agree with your suggested classifications
except for the proposed classification of item 1064-400-094 Carrier Output.
While the 1064-400-094 Carrier Output is referred to as a mechanical component, it is not physically evident
that the item is a gear or any other power transmitting article specifically provided for by the heading. This
item appears to transfer a motion received by a sensor. As the item does not satisfy the terms of heading
8483, it is precluded from consideration within heading 8483.
The applicable subheading for the H466B MOTOR ASSEMBLY will be 8501.31.4000, HTSUS, which
provides for “Electric motors and generators (excluding generating sets): Other DC motors; DC generators,
other than photovoltaic generators: Of an output not exceeding 750W: Motors: Exceeding 74.6 W but not
exceeding 735 W.” The general rate of duty will be 4 percent ad valorem.
The applicable subheading for the 1015-400-215 HOUSING, RESOLVER will be 8503.00.9520, HTSUS,
which provides for “Parts suitable for use solely or principally with the machines of heading 8501 or 8502:
Other: Parts of motors.” The general rate of duty will be 3 percent ad valorem.
The applicable subheading for the H569 Geared Resolver and 25565 Dual RVDT will be 8543.70.4500,
HTSUS, which provides for “Electrical machines and apparatus, having individual functions, not specified or
included elsewhere in this chapter; parts thereof: Other machines and apparatus: Electric synchros and
transducers; flight data recorders; defrosters and demisters with electric resistors for aircraft: Other.” The
general rate of duty will be 2.6 percent ad valorem.
The applicable subheading for the 1064-400-094 Carrier Output will be 7326.90.8688, HTSUS, which
provides for “Other articles of iron or steel: Other: Other: Other: Other: Other.” The general rate of duty will
be 2.9 percent ad valorem.
The duties cited above are current as of this ruling’s issuance. 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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 Howard Suh at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division