The tariff classification of hydrostatic releases fromSweden and Great Britain

NY 875677 July 10, 1992 CLA-2-84:S:N:N1:103 875677 CATEGORY: Classification TARIFF NO.: 8479.89.9099 Mr. Dante F. Versaci II Flagship Trade Services, Inc. 1550 Northwest 96th Avenue Miami, FL 33172 RE: The tariff classification of hydrostatic releases from Sweden and Great Britain Dear Mr. Versaci: In your letter dated June 9, 1992 on behalf of Viking Life Saving Equipment you requested a tariff classification ruling. The Hammar H20 is a disposable mechanical release intended for use with lifeboats. It is designed to release a lifeboat which is attached to a cradle on the deck of a commercial vessel. The H20 consists basically of the hydrostatic release mechanism, several short loops of rope and rope fittings. A short cordage loop which passes through the release mechanism is used to attach the painter line (lifeboat retaining lashing) to the release unit. The hydrostatic release mechanism consists of a reinforced nylon case containing a pressure chamber, pressure membrane and spring-loaded blade. The H20 is activated by water pressure generated at a depth of between 1.5 and 4 meters. If a vessel should begin to sink this pressure will push on the pressure membrane, causing the knife to cut the cordage and thus releasing the lifeboat so that it can float to the water surface. A unique method of regulating air pressure in the pressure chamber is used so that the volume of air is not effected by temperature fluctuations. The H20 is designed to go for two years without maintenance or testing; the expiration date is marked on the outside of the unit's housing. The Berwyn Mark 8 hydrostatic release consists of a quick release snap shackle, 2 additional shackles, a painter line D ring, "weak link" line, and hydrostatic release mechanism. It is designed for use on yachts, power boats, and similar leisure craft, and is intended to operate under water at a depth of between 3 and 19 feet. As the vessel sinks, water pressure releases the draw bolt and D ring so that only the "weak link" (a short length of thin cordage) attaches the liferaft painter line to the body of the release unit. As the vessel continues to sink the painter line is pulled out, which causes the gas cylinder to fire and inflate the liferaft. Under the continuing strain the "weak link" parts, releasing the liferaft which floats to the surface. The applicable subheading for the H20 and Mark 8 hydrostatic releases will be 8479.89.9099, Harmonized Tariff Schedule of the United States (HTS), which provides for other machines and mechanical appliances having individual functions, not specified or included elsewhere.... The rate of duty will be 3.7 percent ad valorem. This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177). A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction. Sincerely, Jean F. Maguire Area Director New York Seaport