CLA-2-87:OT:RR:NC:N1:101
James MacNeill, Senior HTS Classification Analyst
MacNeill Consulting Services
P.O. Box 1214
Bristol, CT 06011-1214
RE: The tariff classification of vehicle fuel delivery system parts from an unspecified country
Dear Mr. McNeill:
In your letter dated February 14, 2014, you requested a tariff classification ruling on behalf of your client, Detroit Diesel Corporation of West Detroit, Michigan.
The items under consideration have been identified as five (5) components used in a vehicle fuel delivery system, which you state supplies fuel to a fuel-injected internal combustion compression-ignition (diesel) engine. You state that the items vary in their construction and their location within the fuel delivery system, but all serve the same basic purpose of conveying fuel between the various components of the fuel delivery system. The items are:
Fuel Tank to Fuel Filter line
Fuel Filter to Fuel Pump hose
Fuel Pump to Fuel Rail pipe
Fuel Rail
Fuel Rail to Injector line
The first item, the Fuel Tank to Fuel Filter (FTFF) line is made of flexible reinforced HTFL nylon tube and is fitted with couplings. Reinforced HTFL tubing consists of a core extrusion of 100% special polyamide containing additives that provide heat and chemical resistance. The core is fiber reinforced using a spiral filament in each direction and is sheathed with a protective layer of 100% specially formulated polyamide polymer containing additives for superior heat and light resistance. The protective layer is fusion bonded to the core tube through the interstices of the spiral fiber reinforcement. The core and cover are of contrasting colors. HTFL tubing and couplings are DOT approved for the distribution of diesel fuel in truck fuel systems. The FTFF line is cut to a specific length to account for limited movement between its end couplings, as is DOT required for such applications. The FTFF line connects to the fuel tank at one end, and the fuel filter module at the other end.
The second item, the Fuel Filter to Fuel Pump (FFFP) hose is made of a FPM plastic inner layer, an HNBR rubber intermediate layer, and a CSM plastic outer layer. It is reinforced with a polymer sealant material and is fitted with a steel elbow hose fitting at both ends. The hose portion is 153 millimeters (mm) in length and each elbow is approximately 77 mm in length, for a total overall length of approximately 307 mm. The hose portion has an inner diameter of 12 mm and an outer diameter of 19mm. The FFFP hose connects at one end to the fuel filter module and at the other end to the high-pressure fuel pump.
The third item, the Fuel Pump to Fuel Rail (FPFR) pipe is a zinc-plated, steel pipe that is cut to size, bent to a specific shape, and fitted with end fittings. The FPFR pipe connects at one end to the high-pressure fuel pump and at the other end to the Fuel Rail. The FPFR pipe has a pressure capacity of up to 1,250 bars (18,130 psi).
The fourth item, the Fuel Rail is a zinc-nickel plated steel cylindrical pipe. It is fitted with a pressure sensor, six ports for fitting connections for each of the six Fuel Rails to Injector lines. There are two ports for fitting connections to the two FPFR pipes, and a pressure-limiting valve with a connector for a return fuel line running back to the fuel pump. The Fuel Rail is attached to the side of the camshaft frame on the engine using brackets and isolators. The fuel injector units are not mounted to the Fuel Rail. Rather they are fixed by means of a hold down clamp inside the camshaft frame. Fuel is directed to the injector units from the Fuel Rail via the FRI lines. The Fuel Rail has a pressure capacity of up to 1,250 bars (18,130 psi).
The fifth and final item, the Fuel Rail to Injector (FRI) line is a zinc-chromate plated steel pipe that is bent to shape and includes fittings. Six of these lines connect from ports on the fuel rail to the individual fuel injectors. Each FRI line has a pressure capacity of 1,250 bars (18,130 psi).
The applicable subheading for the FTFF, FFFP, FPFR, Fuel Rail and FRI will be 8708.99.8180, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of … motor vehicles … : Other parts and accessories: Other: Other: Other: Other: Other: Other.” The general rate of duty is 2.5%.
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 on World Wide Web at http://www.usitc.gov/tata/hts/.
This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Matthew at (646) 733-3013.
Sincerely,
Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division