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 spacer rings 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 aluminum spacer rings, part numbers 8898, 21740, 8145, 12228 and 12600. The spacer rings are used in the Fairchild Model 20 Pneumatic Precision Booster, which is a pneumatic valve that controls the flow of gases. The spacer rings are integral components of the valve, onto which the upper and lower diaphragms of the valve are mounted. Part numbers 8898 and 21740 are circular in shape and part numbers 8145, 12228 and 12600 are paddle shaped. The spacer rings feature a large center hole, an exhaust port through which pressure is released, and six specifically placed holes that allow for the spacer to be mounted to the diaphragm assembly, the bonnet and the valve body. It is mentioned that certain spacer rings have slight physical differences that are required for specific valve options.
In accordance with Note 2(b) to Section XVI, the applicable subheading for the aluminum spacer rings, part numbers numbers 8898, 21740, 8145, 12228 and 12600 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
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