CLA-2-84:OT:RR:NC:N1:102
Ms. Carmen Morrow
Rolls-Royce Commercial Marine
2001 S. Tibbs Ave.
Indianapolis, IN 46241
RE: The tariff classification of valve parts and a pump cartridge from Norway, Sweden and Finland
Dear Ms. Morrow:
In your letter dated January 30, 2012 you requested a tariff classification ruling.
The products under consideration are identified as cartridge valves and a screw pump cartridge. Descriptive literature and photographs were included with your submission.
The first item is described as a pilot operated balanced piston sequence cartridge valve, model number RSFC-LEN. This screw-in hydraulic control cartridge valve consists of three ports: an inlet, an outlet and a drain port. You indicate that the pressure setting of this valve controls the pressure of the inlet port relative to the pressure of the drain port. When the pressure at the inlet port exceeds the valve setting, it forces the drain valve open which regulates the pressure or supplies oil to a secondary circuit.
The second item is described as a fully adjustable pressure compensated flow control cartridge valve with reverse flow check, model number FDCB-LAN. You state that this two port (inlet and outlet) cartridge valve is used for flow control in a hydraulic flow system and provides precise flow regulation for meter-in or meter-out applications. The product incorporates a check valve that provides unrestricted return flow from the outlet port to the inlet port.
In your request, you inquire as to whether or not the cartridge valve is a complete valve since it requires a manifold or block to function as a conventional valve. You suggest classification of the model number RSFC-LEN cartridge valve as either an other pressure reducing valve under subheading 8481.10.0090, Harmonized Tariff Schedule of the United States (HTSUS), an other valve under subheading 8481.80.9050, HTSUS, or as a part of a valve under subheading 8481.90.9085, HTSUS. In addition, you propose classification of the model number FDCB-LAN cartridge valve as a flow control type hydraulic valve under subheading 8481.20.0040, HTSUS, or in the alternative as a part of a valve under subheading 8481.90.9085, HTSUS.
A cartridge valve is a “bodiless” valve imported without a housing. The cartridge contains only the internal moving elements of a valve and requires a cavity such as a valve manifold or block to function as a complete valve. As such, we find that the subject cartridge “valves” are not complete valves but rather parts of valves for the transmission of hydraulic fluid. Valves for the transmission of hydraulic fluid are provided for in subheading 8481.20.00, HTSUS.
The applicable subheading for the cartridge “valves” will be 8481.90.9040, HTSUS, which provides for other parts of the valves of subheading 8421.20. The rate of duty is free.
The third item is described as a Leistritz L3 screw pump cartridge. The pump cartridge is a rotary positive displacement pumping element that is inserted into an installed pump casing. This enables the entire internal pumping mechanism to be replaced without removing the casing or other connections. You indicate that the cartridge is not used with hydraulic power pumps.
You suggest classification of the screw pump cartridge as an other rotary positive displacement pump under subheading 8413.60.0090, HTSUS. However, based on the information made available, we find that the subject pump cartridge is not a pump in and of itself but rather a part of a pump.
The applicable subheading for the screw pump cartridge will be 8413.91.9080, HTSUS, which provides for other parts of pumps for liquids. The 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,
(for)
Thomas J. Russo
Director
National Commodity Specialist Division