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 a spacer ring and a piston from China
Dear Mr. DeCamp:
In your letter dated January 12, 2021, you requested a tariff classification on behalf of your client, A&C Trade Consultants Inc. Descriptive information was provided with your request.
The products under consideration are a spacer ring, part number 21155, and a piston, part number 21119. The spacer ring and piston are said to be used with the Fairchild Model 4800A Pneumatic Volume Booster, which is a pneumatic valve that controls the flow of gases. The spacer ring is circular in shape, and features eight mounting holes, a center hole for air passage, a side threaded port for venting, and an O ring groove on both surfaces. The spacer ring is designed to be installed in between the valve bonnet and diaphragm assembly. The piston is circular in shape, and is described as a part of the control mechanism.
In accordance with Note 2(b) to Section XVI, the applicable subheading for the spacer ring, part number 21155, will be 8481.90.9040, Harmonized Tariff Schedule of the United States (HTSUS), which provided for Taps, cocks, valves and similar appliances, for pipes, boiler shells, 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 is Free.
Pursuant to U.S. Note 20 Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8481.90.9040, 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 subheading 8481.90.9040, 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
Your inquiry does not provide enough information for us to give a classification ruling on the the piston, part number 21119. More information concerning the following questions is needed. Such information includes describing how the controller the piston is used with operates. Is it a motor? What electronic components does the controller consist of? Submit diagrams or pictures that illustrate the location of the piston in regards to the actuator, and the valve.
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