CLA-2-90:OT:RR:NC:N1:105
Anthony Croeker
American Precision Avionics
3815 Prosperity Road
Duluth, MN 55811
RE: The tariff classification of a compass from the United Kingdom
Dear Mr. Croeker:
In your letter dated July 1, 2026, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The item under consideration is the NV2C-28V-SF navigator compass, which is a precision standby
instrument designed for light aircraft, gliders, and microlights. It features an integrated 4-magnet correction
system to minimize magnetic interference from the vehicle’s electrical and mechanical systems. The unit also
utilizes a liquid-damped card housed in silicone-based fluid to eliminate leaks and reduce lead/lag errors,
with metal expansion bellows that compensate for high-altitude pressure changes. Additionally, a fully
adjustable bracket allows for versatile mounting on the glareshield, windshield center post, or canopy,
providing a wide 140° heading view.
Since the compass determines direction using an internal magnetic mechanism rather than electrical currents,
it is categorized as a mechanical direction-finding instrument. The presence of low-voltage electrical
connectors strictly for LED dial illumination does not change the primary function of the device. Adding
supplementary electrical features, such as a light, to a mechanical instrument does not reclassify it as an
electrical device.
The applicable subheading for the NV2C-28V-SF navigator compass will be 9014.10.9000, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for “Direction finding compasses; other
navigational instruments and appliances; parts and accessories thereof: Direction finding compasses: 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 Jason Christie at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division