The tariff classification of parts for wheel loader hydraulic systems of unspecified origin

NY L81368 December 21, 2004 CLA-2-84:RR:NC:1:102 L81368 CATEGORY: Classification TARIFF NO.: 8412.90.9015 Ms. Shannon E. Fura Sandler, Travis & Rosenberg, P.A. Attorneys at Law 225 W. Washington Street (Suite 1550) Chicago, IL 60606 RE: The tariff classification of parts for wheel loader hydraulic systems of unspecified origin Dear Ms. Fura: In your letter dated November 30, 2004 you requested a tariff classification ruling on behalf of your client Volvo Construction Equipment North America (“VCENA”). The articles in question are described as parts of wheel loaders. These parts consist of various pipes designed for use in specific applications on VCENA wheel loaders. You indicate that these parts are identified internally by VCENA as part numbers VOE11172221, VOE 11173847, VOE11015677, VOE11172470, and VOE11023340. Technical drawings of the parts were submitted. Part Number VOE11172221 is a steel oil pipe, which is designed for the hydraulic system of a VCENA wheel loader. Specifically, the part is designed for the lift function of the hydraulic system. The pipe is cold-worked steel of seamless construction, which is bent several times and manufactured with flanges at either end to achieve the requisite configuration for its application in the hydraulic system. Part Number VOE 11173847 is a pipe designed for the return line in the transmission system of the VCENA wheel loader. The pipe is cold-worked steel of seamless construction, which is bent and shaped for its application in the transmission system. We assume from the information made available that the “transmission system” is a hydraulic power system and that the pipe is used to connect the components of that system. Part Number VOE11015677 is similar to Part Number VOE11172221 as it is specifically designed for the lift function of the hydraulic system of the VCENA wheel loader. The pipe is bent in five locations and manufactured with flange fittings at either end for its application in the hydraulic system, which controls the lift function of the VCENA L90 wheel loader. Part Number VOE11172470 is a seamless steel brake pipe, which is manufactured for a VCENA wheel loader. Specifically, this part is a brake pipe, which is designed to function in the front of wheel axle systems of an L110 wheel loader. The pipe at issue is a cold-worked steel of seamless construction, which contains four bends in varying angles to obtain the requisite configuration for its application in the braking system. We assume that the brake pipe is used to connect the hydraulic components of the brake system. Part Number VOE11023340 is a seamless steel brake pipe, which is manufactured for use in the VCENA wheel loader hydraulic brake system. The pipe is cold-worked steel of seamless construction, which is bent in a u-shape configuration for its use and application in the hydraulic braking system. In your request you submit that the pipes are provided for in heading 8431, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of wheel loaders as parts suitable for use solely or principally with the machinery of headings 8425 to 8430. However, we find that the subject parts are more specifically provided for as parts of the hydraulic systems in which they are used. The applicable subheading for the wheel loader pipes, part numbers VOE11172221, VOE 11173847, VOE11015677, VOE11172470, and VOE11023340, will be 8412.90.9015, HTSUS, which provides for other parts of hydraulic power engines and motors. The rate of duty will be free. 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 646-733-3009. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division