CLA-2-84:OT:RR:NC:N1:102
Ms. Darlene E. DiBernardo
A.N. Deringer, Inc.
173 West Service Road
Champlain, NY 12919
RE: The tariff classification of seal kits for valves of unspecified origin
Dear Ms. DiBernardo:
In your letter dated December 13, 2010 you requested a tariff classification ruling on behalf of your client Velan Valve Corporation.
The articles in question are described as four seal kits for valves and identified by representative part numbers SKTE-F04-B2A, SKSB-S15-SSGZ, SKTE-F08-SSE and SKTP-S08-SSEZ. The seal kits include various combinations of thrust and packing washers, packing rings, gaskets, seats, body seals and/or stem bushings that are used in the assembly of valves.
Each of the representative seal kits is specific to a particular size valve and the size of the valve is identified within the body of the assigned part number. Thus, the size of the items included within any given kit imported into the United States and its assigned part number will vary dependent upon the size of the valve with which the kit will be used. However, the configuration of the various seal kits, i.e., type and number of items included, will remain the same as the representative kits. All of the items included in the each of the representative seal kits are imported packaged together in a box or pouch.
In your request you suggest that the seal kits are properly classified in subheading 8484.90.0000, Harmonized Tariff Schedule of the United States(HTSUS), which provides for sets or assortments of gaskets and similar joints. However, because the seal kits contain items, such as packing rings, seats, and stem bushings, which are properly classifiable as parts of the valves with which they are used and not as gaskets or similar joints, the seal kits are not within the scope of subheading 8484.90.0000, HTSUS. We find that the seal kits are classifiable in heading 8481, HTSUS, as sets of components used in the assembly or reassembly of valves.
The applicable subheading for the subject seal kits will be 8481.90.9085, HTSUS, which provides for other parts of taps, cocks, valves and similar appliances. The general rate of duty is 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 ruling, contact National Import Specialist Kenneth T. Brock at (646) 733-3009.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division