CLA-2-84:OT:RR:NC:1:102
Lou Apostolakis
IKEG LLC
P.O. Box 90102
Houston, Texas 90102
RE: The tariff classification of beer dispensing equipment.
Dear Mr. Apostolakis:
In your letter dated October 28, 2014 you requested a tariff classification ruling.
The Keg Coupler, part number KD-2000-D, is described as a tap and it is designed to be mounted onto the top of a Keg. It is said the Coupler contains a silicone flap check valve for the CO2. This valve allows the compressed air to enter the Keg and push out beer. The Coupler also contains a ball check valve and this valve’s function is to open the beer supply and prevent the beer from dispensing when the Keg is unused. The Keg Coupler is comprised primarily of stainless steel and weighs approximately two to three pounds. The Keg Coupler also contains a plastic cover, a solenoid, a pressure transducer, a metal catch, a plastic push flexure, two PCBA circuit boards, rubber gaskets, rubber, chromed brass nuts and ferrules, a metal handle and screws.
In addition to the Keg Coupler, also being imported is a Hub Controller, Power Supply, various lengths of Wires, two Printed Circuit Boards and a Power Distribution Board (PDB) that splits into 8 or 24 jack boards. The wires are designed to provide electricity from the Power Supply to the PDB and also from the PDB to the Keg Coupler. The wires are said to be of 18 to 20 gauges and contain male and female connections.
In your letter, you suggest subheading 8418.69.0130, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other refrigerating, or freezing equipment; Other; Soda Fountain and Beer dispensing equipment. Classification of merchandise under the HTSUS is governed by the General Rules of Interpretation (GRIs) taken in order. GRI 1 provides that classification is determined first in accordance with the terms of the headings and any relative section and chapter notes.
This Office finds the Keg Coupler more specifically provided for as valves, taps and similar appliances in heading 8481. Therefore, the applicable subheading for the Keg Coupler, part number KD-2000-D will be 8481.80.3090, HTSUS, which provides for taps, cocks , valves and similar appliances, hand operated; Of Steel; Other . The duty rate will be 5.6 percent ad valorem.
In regards to the power cables, the applicable subheading for the two conductor 18 gauge wires will be 8544.42.9000, HTSUS, which provides for “Insulated (including enameled or anodized) wire, cable…: other electric conductors, for a voltage not exceeding 1,000 V: fitted with connectors: other: other”. The general rate of duty will be 2.6 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/.
Your inquiry does not provide enough information for us to give a classification ruling on the Hub Controller, Power Supply, two Printed Circuit Boards and the Power Distribution Boards (PDB) that splits into 8 or 24 jack boards. Your request for a classification ruling should include the following information for each:
Samples, photographs, drawings or other pictorial representations of the items as imported. If packaged ready for retail sale, provide the packaging.
Provide descriptive literature and detailed explanations on the use of the items.
Provide a breakdown of components in each device (e.g., microprocessor, circuit board, switches, relays, receptacles, rheostats, potentiometers, semiconductor devices, etc.), please be specific and explain fully.
Explain fully, how each component functions (e.g., radio frequency, infrared, semiconductor components, potentiometers, etc.).
Is the Hub Controller, Power Supply, two Printed Circuit Boards, or the Power Distribution Boards equipped with two or more apparatus of 8535 or 8536 for electric control or distribution of electricity such as switches, relays, fuses surge suppressors, plugs, sockets, lamp-holders and other connectors, junction boxes? Please explain what each component consists of.
Provide product and installation instructions.
When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.
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 Sandra Martinez at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division