The tariff classification of parts of diaphragm valves from Germany

NY B89978 November 6, 1997 CLA-2-84:RR:NC:1:102 B89978 CATEGORY: Classification TARIFF NO.: 8481.90.3000; 8481.90.9060; 8481.90.9080 Mr. R. Kevin Williams O'Donnell, Byrne, Basham & Williams 20 North Wacker Drive (Suite 1416) Chicago, Illinois 60606 RE: The tariff classification of parts of diaphragm valves from Germany Dear Mr. Williams: In your letter dated September 26, 1997 you requested a tariff classification ruling on behalf of your client Alfa Laval Saunders. The items in question are certain valve bodies, identified as "weir type", "straight thru" and "high flow", manual valve bonnets, and actuated valve bonnets. The valve bodies and bonnets are used in assembling completed diaphragm valves. Alpha Laval Saunders assembles and markets three types of diaphragm valves. Each diaphragm valve consists of a body, a diaphragm and a bonnet. The valve bodies are made of various materials, including aluminum, bronze, cast iron, ductile iron, cast alloy steel, and polyvinyl chloride, and may be assembled with either a "manual" or an "actuated" bonnet. The "manual" bonnets utilize a handwheel which is manually turned to open and close the valve. The "actuated" bonnets are designed to accept actuators which use air, water or hydraulic oil pressure to open and close the valve. Both the manual and actuated bonnets are made of cast iron coated with an epoxy finish. You indicate that your client imports and inventories the diaphragm valve components and then assembles the valves in accordance with their customer's specifications. After choosing a particular valve body, the customer would specify a manual or actuated bonnet for the valve. The valve bodies are all completely interchangeable and it is impossible to determine at the time of importation whether a particular valve body will be assembled with a manual or an actuated bonnet. The applicable subheading for the diaphragm valve bodies will be 8481.90.9060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "[t]aps, cocks, valves and similar appliances...: [p]arts: [o]ther...[o]ther: [v]alve bodies." The rate of duty will be 1.5 percent ad valorem. The applicable subheading for the manual valve bonnet will be 8481.90.3000, HTSUS, which provides for "[t]aps, cocks, valves and similar appliances...: [p]arts: [o]f hand operated and check appliances: [o]f iron or steel." The rate of duty will be 6.2 percent ad valorem. The applicable subheading for the actuated valve bonnet will be 8481.90.9080, HTSUS, which provides for "[t]aps, cocks, valves and similar appliances...: [p]arts: [o]ther...[o]ther: [o]ther." The rate of duty will be 1.5 percent 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 Kenneth T Brock at 212-466-5493. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division