CLA-2-84:OT:RR:NC:N1:102
Mr. Gilbert F. Walton
Kidde Fenwal
400 Main Street
Ashland, MA 01721
RE: The tariff classification of control heads of unspecified origin
Dear Mr. Walton:
In your letter dated September 16, 2009 you requested a tariff classification ruling. Descriptive literature and technical drawings were submitted.
The items you plan to import are described as control heads for use on Kidde-Fenwal fire suppression systems equipment. These control heads are specially designed to actuate the valve assemblies that are attached to fire extinguishing agent filled cylinders in order to release the fire extinguishing agent.
Part number WK-870652-000 is a lever operated control head. The lever operated control head is a hand operated valve actuator made of steel. A user pulls the safety pin and then rotates the lever handle. This enables the handle to activate a stem in the body of the assembly. The stem is pushed down into the brass valve and connects to a similar stem which displaces a check seal in the valve assembly. This action releases the fire extinguishing agent from the cylinder.
Part number 82-878737-X00 is a pressure operated control head. The pressure operated control head is a pneumatic actuator. Pneumatic pressure is contained behind a sealed piston which enables the piston to activate a stem in the body of the assembly. The stem is pushed down into the valve and connects to a similar stem which displaces a check seal in the valve assembly. This process allows the fire extinguishing agent to be released from the cylinder.
Part number WK-890181-XX0 is an electric control head assembly. The electronic control head is an electro-mechanical assembly that is electrically or mechanically operated. In the case of electric operation, an electric signal is sent to a solenoid within the control head assembly. The solenoid is de-energized and allows the spring-loaded mechanisms to activate a stem in the body of the assembly. The stem is pushed down into the valve and connects to a similar stem which displaces a check seal in the valve assembly. This action releases the fire extinguishing agent from the cylinder.
In the case of mechanical operation, a user operates the head by pulling a safety pin and rotating the lever handle. The handle allows the spring-loaded mechanisms to activate a stem that is pushed down into the valve. The stem connects to a similar stem which displaces a check seal in the valve assembly which enables the fire extinguishing agent to be released from the cylinder.
The applicable subheading for the lever operated control head will be 8481.90.3000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of hand operated and check appliances of iron or steel. The general rate of duty will be 5 percent ad valorem.
The applicable subheading for the pressure operated control head will be 8412.39.0080, HTSUS, which provides for other pneumatic power engines and motors. The general rate of duty is free.
The applicable subheading for the electric control head assembly will be 8505.90.8000, HTSUS, which provides for "Electromagnets;…; parts thereof: Other, including parts: Other." The general rate of duty will be 1.3 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 Kenneth T. Brock at (646) 733-3009.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division