CLA-2-84:OT:RR:NC:N1:106
Alyssa Koller, Customs Specialist
Rolls-Royce North America Inc.
2001 S. Tibbs Ave.
S/C S-36
Indianapolis, IN 46241
RE: The tariff classification of aircraft engine parts from Great Britain
Dear Ms. Koller:
In your letter dated May 23, 2011 you requested a tariff classification ruling.
The items under consideration have been identified as the control rod and control rod assembly used in the operation of an aircrafts Variable Stator Vanes (VSVs).
The first item, Part Number FW38602, is a control rod and is imported by itself. This component is used to transmit power or movement to the assembly, but is transmitted linearly rather than rotationally as in the case of a transmission shaft. The rod is made of stainless steel, is threaded, each end connects to a rod end bearing, is secured by a nut, and has the appearance of a stud.
The second item, Part Number FW57552, is a control rod assembly and is imported as a complete assembly. The assembly consists of two rod end bearings, two nuts and a threaded rod, all of which are made of stainless steel. The assembly is used to transmit power or movement to the vanes via the unison ring, but is transmitted linearly rather than rotationally as in the case of a transmission shaft.
The control rods allow the connection of all the parts in the actuating mechanism. The VSV Actuator is used to change the orientation of the VSV according to the flight conditions of the aircraft. The VSVs are used to condition the flow of air as it enters the LP Compressor by changing the angle of the blade. This is essential to maintain safe and reliable operation of the engine during changes of thrust, and also optimizes the performance of the engine during steady state operation.
The VSVs operate by the use of two actuators ganged together to control the rotation of a “unison ring”, which provides structural properties, to a position commanded by the Electronic Engine Control (EEC). The actuators are powered by high pressure fuel and a servo valve and are used to control the flow delivered to them. Hydraulic pressure is supplied to both sides of the actuator piston to enable modulation in both directions and close control of position.
In your ruling request you suggest classification of the control rod in either 8483.90.3000, which provides for “Parts of bearing housings and plain shaft bearings: Other”, or 7318.15.5030, which provides for “Studs, of stainless steel”.
Classification of goods in the Harmonized Tariff Schedule of the United States (HTSUS) is governed by the General Rules of Interpretation (GRIs). GRI 1. states “ ... classification shall be determined according to the terms of the headings ... .”
General Note 3. (h) (vi) to the HTSUS states “ ... a reference to “headings” encompasses subheadings indented thereunder.” Subheading 8411.91, provides for “Turbojets, turbopropellers and other gas turbines, and parts thereof:: Parts: Of turbojets or turbopropellers”.
The applicable subheading for part number FW38602 will be 8411.91.1060, HTSUS, which provides for “Turbojets, turbopropellers and other gas turbines, and parts thereof:: Parts: Of turbojets or turbopropellers: Parts of aircraft turbines: For use in civil aircraft”. The rate of duty will be Free.
In addition you suggest classification of the control rod assembly in 8483.30.8055, HTSUS, which provides for “Bearing housings: Plain shaft bearings: Other: Plain shaft bearings: With housings: Rod end bearings”.
Classification of goods in the Harmonized Tariff Schedule of the United States (HTSUS) is governed by the General Rules of Interpretation (GRIs). GRI 1. states “ ... classification shall be determined according to the terms of the headings ... .”
General Note 3. (h) (vi) to the HTSUS states “ ... a reference to “headings” encompasses subheadings indented thereunder.” Subheading 8411.91, provides for “Turbojets, turbopropellers and other gas turbines, and parts thereof:: Parts: Of turbojets or turbopropellers”.
The applicable subheading for part number FW57552 will be 8411.91.1060, HTSUS, which provides for “Turbojets, turbopropellers and other gas turbines, and parts thereof:: Parts: Of turbojets or turbopropellers: Parts of aircraft turbines: For use in civil aircraft”. 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 ruling, contact National Import Specialist Matthew Sullivan at (646) 733-3013.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division