CLA-2-84:OT:RR:NC:N1:104
Lars-Erik A. Hjelm
Akin Gump Strauss Hauer & Feld LLP
Robert S. Strauss Tower
2001 K Street, N.W.
Washington, DC 20006
RE: The tariff classification of angle grinder parts from Germany.
Dear Mr. Hjelm:
In your letter dated January 10, 2020, you requested a tariff classification ruling on behalf of your client, Metabo Corporation (Metabo), for parts of the WE 15-150 Quick Angle Grinder imported separately.
Part number 316069600, the Motor Housing Complete Assembly, is a subassembly that includes electrical subcomponent portions of the angle grinder, specifically the power cord, the brushes, the field coils, and various electronic subcomponents such as electronic controller and switching. The Motor Housing Complete Assembly serves as the angle grinder’s base and supplies power to create a magnetic field within the motor, resulting in the rotation of an armature and other mechanical subcomponents located in the Gear Housing Complete Assembly.
Part number 316069590, the Gear Housing Complete Assembly, is a subassembly that houses mechanical subcomponent portions of the angle grinder’s motor, namely the armature. The Gear Housing Complete Assembly also houses items that are not subcomponents of the motor, such as the spindle, the clutch, a flange, O-rings, pressure rings, retaining rings, washers, and a push button. Those are designed to secure and spin the attached disc, rather than to convert electric energy into mechanical power. The Gear Housing Complete Assembly is a component that consists of a portion of the motor and a portion of the mechanism that the motor serves to power.
Part number 316069600, the Motor Cap, is a plastic housing that affixes to the motor housing subassembly and provides protective cover of the motor.
Part number 316053950, the Shift Lever, is a plastic housing that protects the motor housing subassembly and provides, via an integrated switch, a mechanism to actuate and shut down the angle grinder.
Part number 314000970, the Anti-Vibration Handle, is a handle that allows the user to grip the angle grinder at a location close to its wheel/disc, in turn affording a high degree of control and precision in the grinding and polishing of metal surfaces.
Part number 339204510, the Wheel Guard, is a metal cover that affixes to the flange and provides a partial cover for the wheel/disc, in turn preventing contact between the wheel/disc and the user.
The Motor Housing Complete Assembly, the Gear Housing Complete Assembly, the Motor Cap, the Shift Lever, the Anti-Vibration Handle, and the Wheel Guard are specifically and solely designed for use with the Metabo Angle Grinder and are classifiable in subheading 8467.99, Harmonized Tariff Schedule of the United States, (HTSUS), in accordance with Note 2(b) to Section XVI, HTSUS.
The applicable subheading for the parts described above will be 8467.99.0190, HTSUS, which provides for Tools for working in the hand, pneumatic, hydraulic or with self-contained electric or nonelectric motor, and parts thereof: Parts: 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 the 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 Denise Hopkins at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division