CLA-2-84:OT:RR:NC:N1:102
Jordan Tom
OEC GROUP - ORD Office
555 Pierce Road, Suite 210
Itasca, IL 60143
RE: The tariff classification of a solenoid housing and a valve stem from Taiwan
Dear Mr. Tom:
In your letter dated April 29, 2026, you requested a tariff classification ruling, on behalf of your client, Fasco,
Inc.
The two items at issue are used in electrically operated flushometer valve systems and urinals. Item EL-162
is referred to as a steel solenoid housing with a metal flux plate assembled to it. When it is incorporated into
the solenoid assembly (Item EL-124), item EL-162 houses the solenoid coil. During operation, the metal flux
plate creates a magnetic field which assists the solenoid in actuating the corresponding valve and allowing
water to flow.
In Mitsubishi Electronics America v. United States, 19 CIT 378, 383 n.3 (1995) the court stated, “a subpart of
a particular part of an article is more specifically provided for as a part of a part than a part of the whole.” In
this case, the solenoid housing is “a part of a part” in that it is a part of the solenoid assembly that is itself a
part of the whole, i.e., a valve assembly.
Item number 0301400, as described, is a valve stem that is primarily constructed of stainless steel. It features
a circle-shaped head, has a threaded end and is designed to interconnect with other components to control the
flow of water.
The applicable subheading for the solenoid housing (EL-162) will be 8505.90.7501, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for Electromagnets; permanent magnets and articles
intended to become permanent magnets after magnetization; electromagnetic or permanent magnet chucks,
clamps and similar holding devices; electromagnetic couplings, clutches and brakes; electromagnetic lifting
heads; parts thereof: Other, including parts: Other. The general rate of duty will be 1.3 percent ad valorem.
The applicable subheading for the valve stem (0301400) will be 8481.90.9085, 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: Parts: Other: Other: Other:
Other. The general rate of duty will be Free.
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 Sandra Martinez at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division