Foreign Trade Division rolled out a new search engine, designed and supported by 3CE, a private software company. Trade Division, however, does a poor job of reconciliation of 3CE’s search engine with general rules of interpretation, which should be dispositive in determination of harmonized code (Schedule B included). 3CE engine produces false positives, even for simple products. If one, for example, would try to determine Schedule B number for steel cable ties, 3CE search engine would direct to 7302.90 (Railway or tramway track construction material of iron or steel, the following: rails, check-rails and rack rails, switch blades, crossing frogs, point rods and other crossing pieces, sleepers (cross-ties), fish-plates, chairs, chair wedges, sole plates (base plates), rail clips, bedplates, ties and other material specialized for jointing or fixing rails: Other). Steel cable ties should be classified in the residual category of that chapter (7326). Another example are o-rings. 3CE gives you a choice to classify it as an “article for technical use” or as a “part.” No guidance on either definition is provided. Therefore, if I choose part, I will land somewhere in the landscape of Section XVI, without even knowing about Note 2 requirements of that section. Trade Division…
Actuator may be, prima facie, a part of the valve with which it is used, but actuators for valves, imported / exported separately are not provided in the valve heading 8481. Actuator is a gear assembly and is more specifically provided in heading 8483. Actuator, when presented separately, is 8483.40.5010 HTSUS or 8483.40.4010 Schedule B, which provides for fixed ratio speed changers Source: N025719
Below are useful questions when assessing Schedule B and ECCN determination. While most of them would belong under EAR99, a small minority may be subject to stricter BIS controls. Schedule B What type of bearing is it? (ball w/ integral shaft; ball unground; ball thrust; ball linear; ball angular; ball radial; tapered; spherical; needle; cylindrical) ECCN (2A001) If the bearings is of Radial Ball Type, please advise on each point [yes / no answers only!] whether it is / it has: (1) tolerances specified in accordance with ISO 492 Tolerance Class 2 or better (or ANSI/ABMA Std 20 Tolerance Class ABEC-9, or other national equivalents) and; (2) inner ring bore diameter between 12 and 50 mm; (3) outer ring outside diameter between 25 and 100 mm, and a width between 10 and 20 mm; (4) tolerance specified in accordance with ISO 3290 as grade 5 or worse; (5) made from monel or beryllium; (6) tapered roller bearing; (7) active magnetic? (2A991) If the ball bearings / solid ball bearings have the tolerance specified by the manufacturer in accordance with ABEC 7, ABEC 7P, or ABEC 7T, or ISO Standard Class 4 or better, please advise on each point [yes /…