The classification of a control valve module from Japan

 N313645 August 26, 2020 CLA-2-84:OT:RR:NC:N1:102 CATEGORY: Classification TARIFF NO.: 8481.20.0050 Mr. Joseph Lovegren Shimadzu Precision Instruments, Inc. 3645 N. Lakewood Blvd. Long Beach, California 90808 RE: The classification of a control valve module from Japan Dear Mr. Lovegren: In your letter dated July 31, 2020, you requested a ruling on the classification of a control valve module. The item at issue is a control valve module, part number 732-18570. The control valve module is described as a hydraulic type of module and is used in a commercial airplane lift system. The control valve module is designed to receive input from an input lever. Based on this input, the module controls the flow and direction of hydraulic fluid to hydraulic motors. The control valve module is composed of a bypass valve, a slide and sleeve assembly, a flow regulator assembly, two check valves, an input lever, a shaft, and a valve body. In your letter, you suggest the control valve module is classified under subheading 8481.80.90, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Other appliances: Other. We disagree. Subheading Note 3 to Chapter 84, in relevance, states for the purposes of subheading 8481.20 the expression “valves for oleohydraulic and pneumatic transmissions”, means valves which are used specifically in the transmission of “fluid power” in a hydraulic or pneumatic system. Subheading 8481.20 takes precedence over all other subheadings of heading 8481. In this instance, the subject control valve module transmits hydraulic fluid in a hydraulic system. Accordingly, the applicable subheading for the control valve module, part number 732-18570, will be 8481.20.0050, HTSUS, which provides for Taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Valves for oleohydraulic or pneumatic transmissions: Hydraulic valves: Other. The general rate of duty is 2 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 Sandra Martinez at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division