CLA-2-84:OT:RR:NC:N1:102
Robert D. DeCamp
Sandler, Travis & Rosenberg, P.A.
551 Fifth Avenue, Suite 1100
New York, New York 10176
RE: The tariff classification of pneumatic valve parts from China
Dear Mr. DeCamp:
In your letter dated August 18, 2020, you requested a tariff classification ruling on behalf of your client, A&C Trade Consultants Inc.
The items at issue are a bonnet, part number 7071, and a valve body, part number 7070. The bonnet and valve body are constructed from aluminum material and are used in the Fairchild Model 30 Midget Precision Regulator, which is a pneumatic regulator valve.
The bonnet mounts onto the diaphragm assembly of a valve and functions as an upper enclosure for a valve.
The valve body is a structural components of a valve that features an inlet and an outlet. The valve body is said to be a component of the diaphragm assembly and is precisely machined to accommodate other valve components.
The applicable subheading for the bonnet, part number 7071, will be 8481.90.9040, 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: Parts: Other: Of valves of subheading 8481.20: Other. The rate of duty will be Free.
The applicable subheading for the valve body, part number 7070, will be 8481.90.9020, 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: Parts: Other: Of valves of subheading 8481.20: Valve body. The rate of duty will be Free.
Pursuant to U.S. Note 20 Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 8481.90.9040 and 8481.90.9020, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheadings 8481.90.9040 and 8481.90.9020, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading.
For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at:
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actionshttps://www.cbp.gov/trade/remedies/301-certain-products-china
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. ยง 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