QUESTION: Per the below scenario, what is the membership’s take on compliantly applying GRI 2(a) or GRI 3(b) on the complete, unassembled wear liner? This would essentially declare either subheading 8474.90 or 4016.90 based on the complete liner predominate wear composition. Or should each liner segment be classified (GRI 1)? Scenario: Full wear liner replacement […]
QUESTION: I work for a company that is foreign owned. We have manufacturing sites in several countries. The instruments we manufacture have to be “globally” classified with an HTS number. The instruments we manufacture are not “specifically” named in the HTS headings. We arrive at our classification determination based on the function of the instrument. […]
QUESTION: Who should classify hardware items? Our company routes everything through central trade compliance resources who work with product experts; I have seen other companies train the product experts to do the classifications themselves. I’m looking for other models that may be out there as to who does classifications. And should the same people classify […]
QUESTION: We ship to China an accessory that is part of a set that would qualify as set under GRI 3. The main component of the set is Made in China. The accessory sent from the US to be included in the set is made in Germany. Could we breakdown the set to claim 9801 […]
QUESTION: I have some specialty casing connectors. Is there an argument to be made that they are “Parts Of” drilling equipment under 8431, and not connectors under 7307? They are specifically designed, engineered, and manufactured to be what they are: a precision connection system for casing. They are custom designed for the specific size and […]
QUESTION: We are importing syringes that are used in labs to transfer sample fluid from one tube to the next. These are not used to inject people or humans. Our customs broker advised us that we are still required to classify under 9018.31.0080. Using this HS Code flags for FD2 and AOCs. Is that correct, […]
QUESTION: For articles imported under 9808.00.3000, they are obviously sans duty with the proper DCMA duty-free certificate. Are they also exempt from MPF? ========== Imports qualifying under this HTS are exempt from the MPF Bruce H. Leeds, Esq. Of Counsel Braumiller Law Group PLLC 5220 Spring Valley Rd., Suite 200 Dallas, TX 75254 www.braumillerlaw.com (214) […]
QUESTION: We sell a metal cart that consists of 4 castors, and aluminum lift engine (which is just an extruded piece of metal with a hydraulic lift mechanism to lower and raise the height of the cart), that has and MDF top. I currently have it classified as 9403.20.0090 (metal furniture). However, we have a […]
QUESTION: We take steel pipe, weld on multi-thread box connectors and pin connectors as well as pad eyes and handles eyes to create Transition Joints, Jet Shoe Joints, and Float Shoe joints, all specifically for offshore drilling applications. I believe that we have done enough to create a new and distinct item with specific use, […]
QUESTION: Where would you put a Running Tool (consisting of the Running Tool, Casing Hanger, and Seal Assembly), for Offshore use? Is there any way I can consider it 8431.43.4000 Parts of a Platform? I think, based on CBP rulings on other running tools, that I’m stuck with 8479.89 but I’m hopeful. ========== Answer It […]
QUESTION: When can a seal or o-ring be considered a “part of” something? I’m trying to get my people to understand that most seals are just rubber seals, not a “part of” a valve or other item ************** Answers: Look at the engineering and materials. There are a number of seals and related items found […]
QUESTION: Looking for feedback towards interpreting the GRIs as they apply to aircraft parts. Example scenario: part referred to as a “seal”. This seal, however, may not provide the function of a “seal” in the sense that may not be air tight, but rather fill a gap. These seals are specifically designed for use on […]
