CLA-2-84:OT:RR:NC:N1:102
Joseph Lovegren
Shimadzu Precision Instruments, Inc.
3645 N. Lakewood Blvd.
Long Beach, California 90266
RE: The tariff classification of a hydraulic valve assembly from Japan
Dear Mr. Lovegren:
In your letter dated July 20, 2020, you requested a tariff classification ruling.
The merchandise at issue is a hydraulic valve assembly, part number 99C55620. The valve assembly is used in an aircraft landing gear system and consists of a body, two ports and a poppet and seat assembly. In use, pressure received lifts the valve’s internal poppet to control the flow of hydraulic fluid and the action of the valve’s internal spring force provides the directional control of hydraulic fluid. The valve assembly’s control of fluid allows an actuator to position a truck with an aircraft’s main landing gear door.
In your submission, you suggest that the hydraulic valve assembly is classified in subheading 8481.20.0040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Taps, cocks, valves and similar appliances, for pipes, boilershells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Valves for oleohydraulic or pneumatic transmissions: Hydraulic valves: Flow control type. While we agree that the valve assembly is classified within heading 8481, we disagree at the subheading level, as the valve assembly not only controls the flow of hydraulic fluid, but also provides directional control of hydraulic fluid. Therefore, in accordance with GRI 1, the applicable subheading for the hydraulic valve assembly, part number 99C55620, will be 8481.20.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for valves for oleohydraulic or pneumatic transmissions: hydraulic valves: other. The rate of duty will be 2 percent ad valorem.
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,
Steven A. Mack
Director
National Commodity Specialist Division