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NY A82534




May 28, 1996

CLA-2-84:RR:NC:4:102 A82534

CATEGORY: CLASSIFICATION

TARIFF NO.: 8481.90.3000; 8481.90.9060; 8481.90.9080; 4016.99.6050

Ms. Dawn Gentile
KAT Import Brokers
1310 East Grand Avenue
El Segundo, CA 90245

RE: The tariff classification of parts of either hand operated or actuator operated valves from Denmark

Dear Ms. Gentile:

In your letter dated April 8, 1996, on behalf of your client, American AVK Company, you requested a tariff classification ruling.

The items at issue here are all parts of various sizes and styles of fluid control valves. With the notable exception of rubber coated wedges (gate), all of the parts are of steel. The parts are ultimately incorporated into the domestic production of gate valves, fire hydrants, butterfly valves, and ball valves. While the finished valves are capable of being operated either by hand or by some form of mechanical actuation (hydraulic, electric or pneumatic), the sales data provided with your request clearly demonstrates that the vast majority of valves having inner diameters over 3 inches, are actuated by mechanical means. You also indicate that future shipments of these parts are primarily intended for water works and water treatment industries, an area with heavy usage of portable powered actuators, Additionally, all supplier invoices for parts will be size specific, clearly indicating the diameter of the valve that the part is for. The parts consist of valve bodies, flanges, stems and bonnets.

The only non-metal part to be imported is a thickly rubber-coated wedge used in certain resilient seated gate valves. These wedges are composed of a steel core onto which is layered a substantial covering of rubber. The steel core is there to provide the support structure for the wedge, but the rubber is the component that is shaped and designed to provide the sealing capabilities of the valve. It is our position that it is the rubber that imparts the essential character of the wedge. Headnote l(a) of Section XVI of the Harmonized Tariff Schedules excludes from the Section articles of vulcanized rubber.

The applicable subheading for the rubber-coated wedge will be 4016.99.6050, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of vulcanized rubber, other than hard rubber...other. The rate of duty will be 4.2 percent ad valorem. The various other iron or steel valve parts, if for use with valves having a diameter of 3 inches or less, will be classifiable under HTS subheading 8481.90.3000, which provides for parts of hand operated valves, of iron or steel. The rate of duty will be 6.8 percent ad valorem. Valve bodies, for valves with diameters over 3 inches, will be classified, in your situation, under 8481.90.9060, HTS, which covers parts of other valves, valve bodies. The balance of parts for your valves, with diameters over 3 inches (stems, bonnets, flanges) would be classified under 8481.90.9080, which provides for other valve parts, other. The duty rate for these two subheadings will be 2.2 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 Karl J. Riedl at 212-466-5493.

Sincerely,

Roger J. Silvestri
Director

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