Is it an Aircraft Part? Be Careful About Classification for Imports and Exports!

I get recurring questions about the classification of aircraft parts for both exports and imports. This is a more complicated process than it might seem, at first.

When importing goods, the goods need to be identified with the proper Harmonized Tariff Schedule (HTS) tariff classification. This tariff classification also helps to identify the correct duty that must be paid upon the import of the goods.

When exporting goods, the exporter needs to identify the schedule B number for the goods. These numbers are analogous to the HTS numbers, but they sometimes diverge, so it is also important to look them up separately.

Many ASA members have approached me about whether they can “hit the easy button” and assume that all aircraft-related parts are classified under chapter 88 (which applies to aircraft parts). This would not be correct! Some aircraft parts are classified under other chapters.

When classifying goods under either the HTS or Schedule B, you must select the classification that most accurately describes your goods. For example, if you are importing vulcanized rubber o-rings for use on an aircraft, then you will have a choice between an aircraft parts classification under heading 8807 or:

4016.93.5010: Other articles of vulcanized rubber other than hard rubber: Gaskets, washers and other seals: Other: O-Rings.

Clearly, the O-Rings line in chapter 40 reflects a much more precise description of those O-Rings. It is therefore the more appropriate classification. Some of the places in the HTS and Schedule B where you will find more precise classifications for aircraft parts include the following:

• Tires under heading 4011-4012
• Other rubber products under chapter 40
• Brakes in Chapter 68
• Certain steel, iron, and aluminum products, like fasteners: Codes in chapters 72, 73, and 76
• Aircraft safety glass under subheading 7007.11
• Engines and engine parts under chapter 84
• Stators, rotors, generators and electrical parts under chapter 85
• Certain electronic integrated circuits, including those within heading 8542
• Lithium-ion batteries under subheading 8507.60
• Battery parts under subheading 8507.40
• Inertial Measurement Unit under subheading 9014.20
• Aircraft seats under subheading 9401.10

Each of these may end up being more precise than a classification under heading 8807 (8807 applies to aircraft parts). The classifications under heading 8807 are useful for many aircraft parts, but if there is a more precise and accurate description under another classification then the more precise and accurate description should be the one that it is used.

We will be covering this issue (selection of tariff numbers for imported aircraft parts) in ASA’s tariff webinar, tomorrow.  The ASA webinar will also examine some of the new tariffs, and will discuss how to read a tariff so that you are better prepared for the upcoming tariffs that have been promised. The webinar is free for ASA members please register to make sure you can get a seat), and available for a nominal price to non-members.