CLA-2-84:OT:RR:NC:N1:102
Mr. David Johnson
Hengli America Corporation Inc.
900 E. Diehl Road
Naperville, IL 60563
RE: The tariff classification of dump cylinder and strut cylinders from China.
Dear Mr. Johnson:
In your letter dated October 28, 2013 you requested a tariff classification ruling.
The products you plan to import are described as a telescopic dump cylinder and strut cylinders. You indicate that these cylinders will be assembled onto an off highway truck.
The telescopic dump cylinder is a double-acting, weld fused hydraulic cylinder (motor). It is comprised of multiple tube sections (the largest diameter section called the main or barrel and the smaller tubes that move known as stages), two oil ports/transfer holes, a piston, a flange cap and a seal kit. Hydraulic fluid is applied to both sides of the piston within the cylinder and is used to raise and lower the truck bed in order to empty the truck’s contents.
The strut cylinders consist of a piston rod, a piston head, a piston head locknut, a tube, a flange cap, a round bellows and a seal kit. You state that the off highway truck has two front and two rear struts and that these cylinders are used as the suspension for the vehicle.
The applicable subheading for the telescopic dump cylinder will be 8412.21.0030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other engines and motors, and parts thereof, hydraulic power engines and motors, linear acting (cylinders), weld fused type. The rate of duty will be free.
The applicable subheading for the strut cylinders will be 8708.80.16000, HTSUS, which provides for "Parts…of…motor vehicles…: Suspension system and parts thereof: Suspension systems (including shock absorbers): For other vehicles: Other". The rate of duty will be 2.5 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 telescopic dump cylinders, contact National Import Specialist (NIS) Patricia O’Donnell at (646) 733-3011. If you have any questions concerning the strut cylinders, contact NIS Matthew Sullivan at (646) 733-3013.
Sincerely,
Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division