CLA-2-84:OT:RR:NC:N1:106
T.L. McCracken, Vice President Customs Administration
Supply Chain Shipping, LLC
4607 44th Street S.E.
Kentwood, MI 49512-4010
RE: The tariff classification of trailer landing gear parts from China
Dear Mr. McCracken:
In your letter dated July 28, 2010, you requested a tariff classification ruling on behalf of your client, Wabash National, LP of South Lafayette, Indiana.
The products you intend to import are described as five (5) finished parts of a trailer landing gear. The parts are designed to be assembled onto trailers. They are composed of hot-rolled, cold-finished non-alloy steel. The material chemistry is shown to be from two different designations, grade 50 (340) which has a carbon content of 0.25 and manganese content of 1.35 and grade 80 (550) which has a carbon content of 0.15 and a manganese content of 1.65. The landing gear assembly raises, lowers or supports a semi-trailer during transfers, loading or parked applications.
The first item is described as a cross over shaft, part number 13300671, is used to transfer the leverage applied from one side to the other during raising and lowering applications. It has a 1 inch inside diameter and is 55.38 inches in length. It has attachment holes that are mechanically punched to be used for bolting the cross over shaft between the landing gear legs within the assembly.
The applicable subheading for the cross over shaft, part number 13300671, will be 8431.10.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts suitable solely or principally with the machinery of headings 8425 to 8430: Of machinery of heading 8425: Other. The rate of duty will be Free.
The second item is described as a landing gear brace ear, part number 13s00018; this is the connection point for the bolt on landing gear support braces. It is rectangular in shape and of a solid cross section with two holes drilled at the ends. It is welded to the lifting legs of the assembly.
The applicable subheading for the landing gear brace ear, part 13s00018, will be 7216.91.0010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for angles, shapes and sections, not further worked than cold-formed or cold-finished from flat rolled products, drilled, notched, punched or cambered. The rate of duty will be Free.
The third item has been identified as a crank handle, part number 13300260. This item is used to apply load to the lifting legs of the landing gear assembly and transfers leverage during raising and lowering applications. The attachment holes are mechanically punched in a press and the arm is bent in a forming operation. It is bolted to the landing gear legs within the assembly.
The applicable subheading for the crank handle, part number 13300260, will be 8431.10.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts suitable solely or principally with the machinery of headings 8425 to 8430: Of machinery of heading 8425: Other. The rate of duty will be Free.
The fourth part has been identified as a set of landing gear legs, parts 13200915 and 13200916; these are the actual legs that are used to jack or lift the trailer into position to allow coupling to the tractor. They have multiple mounting holes on both sides of the legs and are intended to be bolted within the assembly.
The applicable subheading for the landing gear legs, parts 13200915 and 13200916, will be 8431.10.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts suitable solely or principally with the machinery of headings 8425 to 8430: Of machinery of heading 8425: Other. The rate of duty will be Free.
The final, part numbered 020002706, has been identified as an “X-Sill” or cross member. This is a straight piece resembling a channel with plates attached at each end. The cross members are fitted to the bottom side rails of a trailer to support the floor. It will be bolted both within the landing gear assembly and trailer.
The applicable subheading for the cross member, part 020002706 made from grade 50 (340) material will be 7301.20.1000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for sheet piling of iron or steel, whether or not drilled, punched or made from assembled elements; welded angles, shapes and sections, of iron or steel: angles, shapes and sections: of iron or nonalloy steel. The rate of duty will be free.
The applicable subheading for the cross member, part 020002706 made from grade 80 (550) material will be 7301.20.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for sheet piling of iron or steel, whether or not drilled, punched or made from assembled elements; welded angles, shapes and sections, of iron or steel: angles, shapes and sections: of alloy steel. The rate of duty will be free.
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 landing gear legs, crank handle or cross over shaft, contact National Import Specialist Mark Palasek at (646) 733-3013. If you have any questions regarding the cross members or landing gear brace ear, contact National Import Specialist Mary Ellen Laker at 646-733-3020.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division