CLA-2-70:OT:RR:NC:1:126
Ms. Alyssa Koller
Rolls-Royce North America
2001 S. Tibbs Avenue
Speed Code S36
Indianapolis, IN 46241
RE: The tariff classification of three fiberglass insulating products from Great Britain
Dear Ms. Koller:
In your letter dated May 9, 2008, you requested a tariff classification ruling. Three representative samples were submitted and were sent to our U.S. Customs and Border Protection laboratory for analysis. Our laboratory has now completed its analysis.
The subject article, designated as “Heatshield Shim” - part number FK24528, is described as an insulation blanket used in the low pressure area of a gas turbine engine. Our Customs laboratory has determined that the article is composed of a thin steel exterior with a non-woven fiberglass interior. You state in your letter that temperatures near the low pressure section of the engine can reach up to 490º Celsius and ultimately reach as high as 1,390º Celsius in a hot section of the engine. The fiberglass component within the insulation blanket provides thermal protection.
The subject article, designated as “Insulation Blanket” - part number 1-06801-00-00, is described as a thermal insulation blanket designed with a function to protect the low pressure turbine bearing and support housing from heat generated within the turbine. Our Customs laboratory has determined that the article is composed of a steel exterior with a non-woven fiberglass interior.
The subject article, designated as “Insulation Strip” - part number UL23795, is an insulating strip (smaller in width than a blanket). Our Customs laboratory has determined that the item consists of, from the outside in, a nylon bag with a woven layer of fiberglass, a second nylon bag, a non-woven fiberglass mat and a non-woven fiberglass felt. You state in your letter that this article provides thermal protection as in product (part number FK24528).
The essential character of all three products is imparted by the non-woven insulating fiberglass component. The non-woven fiberglass component within each article provides the thermal insulation protection for the glass turbine engine.
In your letter you suggest classification under subheading 8411.91.9080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for turbojets…and other gas turbines, and parts thereof: parts: of turbojets…: other: parts of aircraft gas turbines: other. This is not correct. The articles under review provide insulation to the turbine engines in various ways, however they are not necessary to the completion of the engine, as the engine is capable of functioning without these articles.
The applicable subheading for the Heatshield Shim - part number FK24528, Insulation Blanket - part number 1-06801-00-00 and Insulation Strip - part number UL23795 will be 7019.39.10, HTSUS, which provides for glass fibers (including glass wool) and articles thereof…thin sheets (voiles), webs, mats, mattresses, boards and similar non-woven products: other: insulation products. The rate of duty will be 4.9 percent ad valorem.
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 Jacob Bunin at 646-733-3027.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division