The tariff classification of pneumatic valve parts from China

N314016 September 14, 2020 CLA-2-84:OT:RR:NC:N1:102 CATEGORY: Classification TARIFF NO.: 8481.90.9040, 8481.90.9020, 9903.88.01 Robert D. DeCamp Sandler, Travis & Rosenberg, P.A. 551 Fifth Avenue, Suite 1100 New York, New York 10176 RE: The tariff classification of pneumatic valve parts from China Dear Mr. DeCamp: In your letter dated August 18, 2020, you requested a tariff classification ruling on behalf of your client, A&C Trade Consultants Inc. The items at issue are a bonnet, part number 19479, the valve body, part number 19501, and spacer rings, part numbers 21470, 8145, 12228, 12600 and 8898. The bonnet, valve body, and spacer rings are of aluminum material and are used in the Model 20 Pneumatic Precision Booster, which is a pneumatic valve. The bonnet is described as the valve’s enclosure and is designed to mount onto the diaphragm assembly of the valve. The valve body is a structural component of the valve that features an inlet and an outlet. The valve body is also described as the component in which other components are placed within. Some of the components installed into the valve body are the seal plate assembly, the seat assembly and inner valve assembly. The spacer rings are designed to give the pneumatic valve extra room. The applicable subheading for the bonnet, part number 19479, will be 8481.90.9040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Taps, cocks, valves and similar appliances, for pipes, boilershells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Parts: Other: Of valves of subheading 8481.20: Other. The rate of duty will be Free. The applicable subheading for the valve body, part number 19501, will be 8481.90.9020, HTSUS, which provides for Taps, cocks, valves and similar appliances, for pipes, boilershells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Parts: Other: Of valves of subheading 8481.20: Valve body. The rate of duty will be Free. Pursuant to U.S. Note 20 Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 8481.90.9040 and 8481.90.9020, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheadings 8481.90.9040 and 8481.90.9020, HTSUS, listed above.The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at: https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actionshttps://www.cbp.gov/trade/remedies/301-certain-products-china Your inquiry does not provide enough information for us to give a classification ruling on the spacer rings, part numbers 21470, 8145, 12228, 12600 and 8898. Please provide additional information that describes the physical features of the spacers. Submit pictures or photographs that illustrate the spacers from all sides and angles. Explain why the M20 Pneumatic Precision Booster cannot operate without the presence of the spacers. Clearly describe the physical features that prevent the spacers from being used in other applications. 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 Sandra Martinez at Sandra.martinez@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division