The tariff classification of a metal shaft and a tappet gear assembly from Germany

N360918May 14, 2026CLA-2-85:OT:RR:NC:N2:220
CATEGORY: Classification
TARIFF NO.: 8483.10.5000; 8537.20.0040
Mr. P. SmithBaker, Donelson, Bearman, Caldwell & Berkowitz, PC901 K Street, N.W., Suite 900Washington, DC 20001RE: The tariff classification of a metal shaft and a tappet gear assembly from GermanyDear Mr. Smith:In your letter dated
April 22, 2026
, you requested a tariff classification ruling on behalf of your client,Reinhausen Manufacturing, Inc.There are two items at issue in this request, part number 71290001, a metal shaft, and part number1000321101, a tappet gear assembly, which you state are specially designed for use with an on-load tapchanger (OLTC).Part number 71290001 is a solid metal shaft that features calibrated indents on both ends and a keyconnection that ensures the proper transmission of rotational power. The shaft, which is installed in the centerbore of a helical gear, transmits rotational power to a coupling to change the impedance of a transformeroperating 26.4 kV.in excess ofPart number 1000321101 is a tappet gear assembly that includes a gear system, cams, and micro switches(cam switches). The gear system drives a series of cams which in turn operate the micro switches. The camsand micro switches are assembled between two metal mounting plates, while the gear assembly is situated oneither side of the mounting plates. In use, the tappet gear assembly functions as a safety timing system toprevent electrical flashover for transformers operating in excess of 26.4 kV. Research indicates that camswitches in an OLTC ensure precise, sequential operation of the tap changer's components. The cam switchesmanage the electrical control circuit, detecting positions and initiating the correct sequence of motorcontactors to change transformer taps without interrupting the loaelectrical d.In your letter, you suggest that in accordance with Note 2(b) to Section XVI, the shaft and tappet gear classified within subheading 8538.90.8180, Harmonized Tariff Schedule of the United Statesassemblyare(HTSUS), which provides for arts suitable for use solely or principally with the apparatus of heading 8535,“P8536 or 8537: Other: Other: Other: Other: Other. We disagree.”
Note 2 to Section XVI, in relevance, states that subject to note 1 to this section, note 1 to chapter 84 and tonote 1 to chapter 85, parts of machines (not being parts of the articles of heading 8484, 8544, 8545, 8546 or8547) are to be classified according to the following rules:(a) Parts which are goods included in any of the headings of chapter 84 or 85 (other than headings 8409,8431, 8448, 8466, 8473, 8487, 8503, 8522, 8529, 8538 and 8548) are in all cases to be classified in theirrespective headings;(b) Other parts, if suitable for use solely or principally with a particular kind of machine, or with a number ofmachines of the same heading (including a machine of heading 8479 or 8543) are to be classified with themachines of that kind or in heading 8409, 8431, 8448, 8466, 8473, 8503, 8522, 8529 or 8538 as appropriate.However, parts which are equally suitable for use principally with the goods of headings 8517 and 8525 to8528 are to be classified in heading 8517, and parts which are suitable for use solely or principally with thegoods of heading 8524 are to be classified in heading 8529;Based on the hierarchy established by Note 2 to Section XVI of the HTSUS, heading 8538 is not applicablefor th shaft.Shafts designed for power transmission are specifically provided foris or tappet gear assembly under heading 8483, hich is in accordance with Note 2(a) to Section XVI.w The tappet gear assembly isfunctionally described in heading 8537 as a base with two or more apparatus of heading 8535 for electrichich is in accordance with Note 2(a) to Section XVI.control, wThe applicable subheading for the shaft, part number 71290001, will be 8483.10.5000, HTSUS, whichprovides for ransmission shafts (including camshafts and crankshafts) and cranks; bearing housings,“Thoused bearings and plain shaft bearings; gears and gearing; ball or roller screws; gear boxes and other speedchangers, including torque converters; flywheels and pulleys, including pulley blocks; clutches and shaftcouplings (including universal joints); parts thereof: Transmission shafts (including camshafts andcrankshafts) and cranks: Other transmission shafts and cranks. The general rate of duty will be Free.”The applicable subheading for the tappet gear assembly, part number 1000321101, will be 8537.20.0040,HTSUS, which provides for “Boards, panels, consoles, desks, cabinets and other bases…for electric controlor the distribution of electricity... For a voltage exceeding 1,000 V: Other.” The general rate of duty will be2.7 percent ad valorem.The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenienceand are subject to change. The text of the most recent HTSUS and the accompanying duty rates are providedat https://hts.usitc.gov/.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties 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 eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems 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 asidentified 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 andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Gary Chaffee at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division