CLA-2-40:OT:RR:NC:4:421
Mr. John Brew
Crowell & Moring, LLP
1001 Pennsylvania Avenue NW
Washington, DC 20004
RE: The tariff classification of hose assemblies from Japan
Dear Mr. Brew:
In your letter dated July 10, 2015, on behalf of Hino Motors Manufacturing U.S.A., you requested a tariff classification ruling.
The four products at issue in your submission are identified as parts for commercial trucks. You describe three of the four products as hose subassemblies that are intended for use with a vehicle’s catalytic converter; the fourth product is identified as a master cylinder assembly.
Part number 87209E0A80 consists of an inner hose of ethylene tetrafluorine (ETFE) plastic and polyamide-12 nylon, covered in part by a corrugated plastic tube. The component has three connectors, two for fluids and one for electricity, and is designed to circulate and deliver DEF fluid (urea water) to a catalytic converter system. The component heats the fluid that it delivers by means of a copper wire that runs through the length of the inner hose and attaches to the electrical connector.
Part number 87209E0B10 consists of an inner hose of ethyl propylene diene monomer (EPDM) rubber reinforced by textile material. A portion of the hose is covered by a corrugated plastic tube, and one end of the hose has a plastic connector. The component is designed to circulate and deliver DEF fluid to a catalytic converter system.
Part number 87245E0L30 consists of a hose of textile-reinforced EPDM rubber. The hose contains no connectors and is notched on one end. The component is designed to deliver coolant to the nozzle that injects DEF fluid into the catalytic converter system, to prevent said nozzle from overheating.
In your submission you indicate that the above components are shaped to fit around a specific model of catalytic converter, and thus suggest classification in 8421.99.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Parts: Other: Other. However, the subject hose assemblies serve merely to deliver fluids to the catalytic converter. The catalytic converter is a complete and separate entity in and of itself, and appears to function independently of the hose assemblies at issue. As a result, classification in 8421.99.0080, HTSUS would not apply for the subject hose assemblies.
The applicable subheading for part number 87209E0A80 will be 8708.99.8180, HTSUS, which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other: Other. The general rate of duty will be 2.5% ad valorem.
The applicable subheading for part number 87209E0B10 will be 4009.32.0050, HTSUS, which provides for tubes, pipes and hoses, of vulcanized rubber other than hard rubber…reinforced or otherwise combined only with textile materials: with fittings, other. The rate of duty will be 2.5 % ad valorem.
The applicable subheading for part number 87245E0L30 will be 4009.31.0000, HTSUS, which provides for tubes, pipes and hoses, of vulcanized rubber other than hard rubber…reinforced or otherwise combined only with textile materials: without fittings. The rate of duty will be 2.5 % 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/. With regard to your request for the classification ruling of the master cylinder assembly, please be advised that the classification of similar merchandise is currently being reviewed by OR&R at CBP Headquarters. As such, this office is precluded from ruling on the classification of the merchandise at this time.
You may, however, resubmit your request for a prospective classification ruling of these items upon the publication of a final ruling determination by CBP Headquarters.
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 Evan Conceicao at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division