CLA-2-90:OT:RR:NC:N1:105
Lori Higgs
Air Gaging LLC
1050 N. Riverside Drive, Suite B
Freeport, IL 61032
RE: The tariff classification of an air gauge column and related components from Germany
Dear Ms. Higgs:
In your letter dated November 20, 2017, you requested a tariff classification ruling.
Your submission concerns four products, identified as an MSM Mini Measuring Column, an SPW Rapid Transducer, an Air Jet Ring for Taper HSK, and a Master Taper Mandrel. The products are components of an air gauging measurement system designed to provide accurate dimensional measurements of manufactured parts.
The MSM Mini Measuring Column, also referred to as an air gauge column, is used to perform precise measurements of manufactured components. Compressed air passes through the air gauge column and flows out of the nozzle of an attached tool (such as a mandrel, ring, or probe). When a manufactured part is placed near the nozzle, the air gauge column can determine its internal dimensions by analyzing the back pressure in the air flow. The product is capable of measuring variables such as diameter, taper, etc., of an item with a high degree of precision, and can display the measurement readings on an inbuilt color touchscreen monitor. Air gauge columns of this type are said to be used by the automotive, aerospace, and medical industries when manufacturing precision components.
The SPW Rapid Transducer is described as a pneumatic electronic transducer that is said to perform the same measurement function as the abovementioned measuring column, though the product lacks a display. When combined with a pneumatic tool, such as a mandrel, the product can determine the dimensional measurements of a manufactured part by analyzing the back pressure in the air flow via an inbuilt pressure sensor. The SPW Rapid Transducer converts the back pressure reading into a voltage signal by which the dimensional measurements can be ascertained. The product is typically used in situations where a display is not required, and can send the measurement data it collects to a computer for display and review purposes.
The Air Jet Ring for Taper HSK and the Master Taper Mandrel are both hard chrome plated components that are designed to be attached via hoses to an air gauge column or a pneumatic-electronic transducer. The two components are used to assist in the measurement of manufactured parts (the type of part to be measured, and its dimensions, will determine which tool to use in the measurement process).
In your submission you suggest classification of the abovementioned products in heading 9026, Harmonized Tariff Schedule of the United States (HTSUS), which provides for instruments and apparatus for measuring or checking the flow, level, pressure, or other variables of liquids or gases. Based on the information provided, it does not appear that the products covered by your submission would be appropriately classified in that heading. The Harmonized System Explanatory Notes to Heading 9026 indicate that the heading includes apparatus for measuring the pressure of a liquid or gas. The MSM Mini Measuring Column and SPW Rapid Transducer do not provide a measurement of the level of air pressure (e.g., in pounds per square inch), rather they rely on an analysis of back pressure to determine dimensional measurements. In this respect the products serve a function similar to that of the instruments described in Explanatory Note (I)(A)(7) to Heading 9031, which includes electronic and pneumatic sensors for measuring length, angles, or other geometrical quantities. Additionally, Customs has previously classified an air column gauge that operated on similar principles in heading 9031 in New York Ruling Letter 871973, dated March 23, 1992.
The applicable subheading for the MSM Mini Measuring Column and the SPW Rapid Transducer will be 9031.80.8085, HTSUS, which provides for Measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors; parts and accessories thereof: Other instruments, appliances and machines: Other: Other. The rate of duty will be 1.2% ad valorem.
The applicable subheading for the Air Jet Ring for Taper HSK and the Master Taper Mandrel will be 9031.90.9195, HTSUS, which provides for Measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors; parts and accessories thereof: Parts and accessories: Other: Other: Other: Other. 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 https://hts.usitc.gov/current.
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,
Steven A. Mack
Director
National Commodity Specialist Division