CLA-2-83:RR:NC:MM:101 G86865
Mr. Kevin Hussey
Schenker, Inc.
Philadelphia Branch
Alexander Court 1, Bay 1-5
850 Calcon Hook Road
Sharon Hill, Pennsylvania 19079
RE: The tariff classification of components used in the manufacture of Pneumatic Cylinders: End Fitting, Valve Stem, Bar Round, and a Blank Pin Actuator from Germany
Dear Mr. Hussey:
In your letter dated February 5, 2001 you requested a tariff classification ruling.
You submitted samples and brochures of components used in the manufacture of Pneumatic Cylinders: End Fitting, Valve Stem, Bar Round, and a Blank Pin Actuator. You state that these pneumatic cylinders are utilized in furniture and industrial applications; however, they are principally used in the automobile industry. One of the applications on which these pneumatic cylinders is for automotive rear hatches.
The first component is called the End Fitting and it is made of plastic. It is used as an external piece which attaches to the inner rod of the cylinder and when pulled permits the rod to move up and down inside the cylinder. You suggest HTS 3926.90.9880.
The second component is called a Valve Stem and is made of base metal. It is used inside the cylinder as a valve body that is used to regulate the pressure to accommodate the task being performed by the cylinder. You suggest HTS 8481.90.9020.
The third component is called a Bar Round and is made of base metal. The part is used to move the valve up and down through the cylinder while the cylinder is operating. You suggest HTS 8481.90.9040.
The fourth component is called a Blank Pin Actuator and is made of base metal. It is used to move the valve up and down through the cylinder while the cylinder is operating. You suggest HTS 8481.90.9040.
The applicable subheading for the End Fitting will be 3926.90.9880, Harmonized Tariff Schedule of the United States (HTS), which provides for Other articles of plastic and articles of other materials of headings 3901 to 3914: Other: Other…Other. The rate of duty will be 5.3% ad valorem.
We disagree with you proposed classifications for the Valve Stem, Bar Round, and Blank Pin Actuator.
The applicable subheading for the Valve Stem, Bar Round, and Blank Pin Actuator will be 8302.30.3060, Harmonized Tariff Schedule of the United States (HTS), which provides for Base metal mountings, fittings and similar articles suitable for furniture, doors, staircases,…, coachwork…; and base metal parts thereof: Other mountings, fittings and similar articles suitable for motor vehicles; and parts thereof: Of iron or steel, of aluminum or of zinc…Pneumatic cylinders for lifting, lowering, dampening or counter-balancing…Other. The rate of duty will be 2% 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 Robert DeSoucey at 212-637-7035.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division