The tariff classification of a rotary geared actuator from the United States

N359923 April 15, 2026 CLA-2-88:OT:RR:NC:N2:206 CATEGORY: Classification TARIFF NO.: 8807.30.0030 Cody Miller Curtiss-Wright Actuation Division 201 Old Boiling Springs Rd. Shelby, NC 28152 RE: The tariff classification of a rotary geared actuator from the United States Dear Mr. Miller: In your letter dated March 20, 2026, you requested a tariff classification ruling. The item under consideration has been identified as a Rotary Geared Actuator, Part Number 178800-xxx, also called a flap actuator assembly, is comprised of a two-stage gear reduction system, that operates the leading-edge flaps of the Boeing 747 aircraft. The actuator functions to transmit flap drive torque to the linkage system of the lead edge flaps. Each unit is driven by torque from a torque tube. Torque tube rotary motion is also transmitted through the actuator assembly to the next inline actuator. The actuator is situated along with the bay door drives, and also can be used for controlling leading or trailing edge movements of the aircraft. It receives power drive unit torque via assembly of shafts and joints. From a mechanical standpoint, the actuator can be termed as an epicyclical gear reducer or compound planetary gearbox. The 178800-xxx is purely mechanical and does not include any hydraulics, pneumatics, or electronics. It functions based on standard gearing principles providing a specific gear ratio in a smaller form factor. It does not rely on an external hydraulic or pneumatic power source in order to operate. It does not include a valve, a motor or a position sensor. The actuator is situated along with the bay door drives, and also can be used for controlling leading or trailing edge movements of the aircraft. It receives power drive unit torque via assembly of shafts and joints. From a mechanical standpoint, the actuator can be termed as an epicyclical gear reducer or compound planetary gearbox. You state that the 178800-xxx actuator was manufactured in the United States; however, it is not currently in production. It will be imported into the United States for repair or overhaul from Boeing 747 aircraft operators in Japan, Germany, Luxembourg, Hong Kong, and other countries. You presented two headings under the Harmonized Tariff Schedule of the United States (HTSUS) for the rotary geared actuator: heading 8483, HTSUS, which provides for gear boxes and other speed changers, including torque converters, and heading 8807, HTSUS, which provides for parts of aircraft. You suggest that the rotary geared actuator is correctly classified in heading 8807, because “Note 1(l) to Section XVI excludes articles of Section XVII, which includes aircraft and its parts, from this section. Furthermore, the Explanatory Notes to heading 8483 exclude, "Transmission equipment of the kinds described above (gear boxes, transmission shafts, clutches, differentials, etc.), but which are designed for use solely or principally with vehicles or aircraft (Section XVII); it should, however, be noted that this exclusion does not apply to internal parts of vehicle or aircraft engines - these parts remain classified in this heading."” We agree. The applicable subheading for the Rotary Geared Actuator, Part Number 178800-xxx, will be 8807.30.0030, HTSUS, which provides for “Parts of goods of heading 8801, 8802, or 8806: Other parts of airplanes, helicopters or unmanned aircraft: For use in civil aircraft: Other.”. The general rate of duty will be Free. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Liana Alvarez at liana.alvarez@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division