I have a question regarding the use of Schedule B Codes relating to spare parts.
We manufacture compressor systems and sell a majority of them with accessories that enable the system to perform. These accessories could be stainless steel 90° elbows or a rubber drive belt.
When we export an entire system with parts we classify it under Schedule B Code [8414.30.1080] with the accessories included under the same code since it is an item that has been dissembled under GRI 2a. We've never had a question about these classifications.
When we sell just a drive belt alone, we've been classifying it under the code identified as parts [8414.90]. Is this correct?
Confused About Our Code
Dear Confused About Your Code:
These types of questions require more information in order for me to form a reply. Often, underlying details change an answer from one classification to another.
The Schedule B Code and Harmonized Tariff Schedule of the U.S. and the General Rules of Interpretation direct companies to the Section and Chapter Notes. Section XVI Notes and Chapter 84 Notes ask that we classify items that are named in the tariff to go to the specific headings where the goods can be found. This is reinforced by U.S. Note 1 to classify items within their appropriate headings.
For example, Chapter 73 has Heading 7307 that states, "Tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel." This heading, plus your internal drawings and bill of materials would direct me to likely classify the elbow (if shipped on its own) within Chapter 73 under Heading 7307. We need more information to make a decision about the 10-digit classification.
There are some great tools for you to use to help determine the classification of the individual item. These are tools that will help you make decisions based on the General Rules of Interpretation of the Schedule B Code:
This tool allows you to enter a brief description of your product, and then it asks you questions about your product to drill down to the proper code.
This is a search engine that links to the Harmonized Tariff Schedule of the U.S.
Customs and Border Protection (CBP) has published a series of "Informed Compliance" documents that provide guidance to exporters and importers as they identify the correct classification for specific types of products.
CBP also publishes a full listing of classification ruling letters it has issued. It can be used as guidance for classifying your own products.
There are many different ways you may need to classify your products in international trade. In addition to finding the correct Schedule B or HTS code, you need to identify if your product has an Export Control Classification Number (ECCN) or U.S. Munitions List (USML) code before you can determine if your product requires an export license before it can legally leave the U.S. The Product Classification Wizard allows you to search for all these different codes, as well as map the 10-digit HTS code from the U.S. to any other country, all in one place.
All the best with your efforts!
This article was first published in April 2011 and has been updated to include current information, links and formatting.