The tariff classification of components used in the manufacture of Pneumatic Cylinders: a Tube End, a Body, a Piston/Labyrinth, a Pin Actuator, and a Rod from Germany

NY G86866 February 26, 2001 CLA-2-83:RR:NC:MM:101 G86866 CATEGORY: Classification TARIFF NO.: 3926.90.9880, 8302.30.3060 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: a Tube End, a Body, a Piston/Labyrinth, a Pin Actuator, and a Rod 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: a Tube End, a Body, a Piston/Labyrinth, a Pin Actuator, and a Rod. 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 a Tube End and is made of base metal. It is used on the end of the cylinder tube. You suggest a classification of HTS 8302.49.6085. The second component is called a Body and is made of base metal. It is incorporated inside of the cylinder as a valve body that is used to regulate the pressure to accommodate the task being performed by the cylinder. You suggest a classification of HTS 8481.90.9020. The third component is called a Piston/Labyrinth and is made of plastic. It is used inside of the cylinder as a part of the valve. You suggest a classification of HTS 8481.90.9040. The fourth component is called a 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 a classification of HTS 8481.90.9040. The fifth component is called a Rod 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 a classification of HTS 8481.90.9040. We disagree with your classifications of a Tube End, a Body, a Piston/Labyrinth, a Pin Actuator, and a Rod . The applicable subheading for the Piston/Labyrinth 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. The applicable subheading for the Tube End, the Body, the Pin Actuator, and the Rod 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