CLA-2-84:OT:RR:NC:N1:104
Minseok Choi
Onestop Customs Corporation
D-706-ho, 700, Pangyo-ro, Bundang-gu, Seongnam-si, Gyeonggi-do, 13516 South Korea
RE: The tariff classification of an aluminum valve block from South Korea.
Dear Mr. Choi:
In your letter dated April 5, 2024, you requested a tariff classification ruling on behalf of your client, HL Mando Corporation.
The subject item is a valve block, which you also refer to as a BAU block. The valve block is comprised of grade 6061-T6 aluminum extrusion material and is part of an electronically controlled all-in-one Integrated Dynamic Brake (IDB) assembly that was addressed by this office in a previous ruling, N332229 (Apr. 28, 2023). As noted in N332229, the IDB assembly is installed on a vehicle and combines the functions of the conventional vacuum booster brake and electronic stability control (ESC). In addition to the valve block, the IDB is comprised of a mounting assembly, motor and ball screw, pump piston assembly, pump housing, solenoid valve, pressure sensor, brake fluid reservoir, and a fully integrated electronic control unit (ECU).
You describe the valve block as a rectangular parallelepiped product that is a component of the IDB. It is drilled so that other components such as valves can be fastened to it. The product's interior also has a hole in it so that hydraulic pressure and brake oil generated by the operation of the ECU, motor, and pump flow through the assembled parts. Additionally, the valve block also provides the basis for connecting the mounting plate assembly so that the IDB to which each part is fastened can be mounted on the vehicle. In N332229, we determined that the IDB assembly was classified in subheading 8479.89.9596, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other machines and mechanical appliances having individual functions, not specified, or included elsewhere in Chapter 84.
In your letter, you suggest that the valve block is classified within subheading 8481.90.9020, HTSUS, which provides 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: Valve bodies. We disagree, as it is not an integral component part of the valves or valve system, but rather part of a hydraulic system that incorporates valves and other system components. Features of the block that support this premise are the interior oil path it provides for the system, the internal opening that aids in the generation of hydraulic pressure produced by the various system components and its design, which allows the complete system to be mounted into its respective location within the vehicle. Based on the foregoing considerations, the valve block is not an integral component part of the valves or valve system and thus, excluded from heading 8481.
Alternatively, you suggest that the valve block may properly be classified in subheading 7616.99.5190, HTSUS, which provides for other articles of aluminum, other . . . other. We disagree. Heading 7616, HTSUS, is a residual or basket provision which covers a wide range of aluminum articles that are not more specifically provided for in any other heading in the HTSUS. As the subject valve block is more specifically provided for under heading 8479, HTSUS, the product would not be classified under heading 7616, HTSUS.
When imported separately from the IDB, the proper subheading for the valve block will be subheading 8479.90.9596. HTSUS, which provides for Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Parts: Other: 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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Arthur Purcell at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division