Harmonized Tarrif Codes for Engines and Engine Parts

ASA Members are frequently confused about what are the right tarrif codes for aircraft engine parts. This can be a complicated area, and a number of tarrif rulings have provided guidance in this area.  Aircraft engines usually fit into an engine-specific tariff code, like one of these:

  • 8411.11.4000  turbojet engines for aircraft; thrust not exceeding 25 kN
  • 8411.12.4000  turbojet engines for aircraft; thrust exceeding 25 kN
  • 8411.21.4000  turboprop engines for aircraft; power not exceeding 1,100 kW
  • 8411.22.4000  turboprop engines for aircraft; power exceeding 1,100 kW
  • 8411.81.4000  other gas turbine engines for aircraft; power not exceeding 5,000 kW
  • 8411.82.4000 other gas turbine engines for aircraft; power exceeding 5,000 kW

Engine parts, on the other hand, usually fit into parts-specific tariff codes.  Articles that are integral, constituent or component parts without which the article with which they are used cannot function have been held to be “parts” for tariff purposes.  Thus gas turbine engine parts may fit into one of the “8411.91” or “8411.99” categories. An example of a part thath could not be described as an engine part would be a “stud” fastener used in Rolls Royce engines, which was characterized under tariff code 7318.15.50.  Classificiation HQ 957549  (May 12, 1995).  One of the factors that caused the government to characterize the stud as a general fastener instead of as an engine part was the fact that there was no evidence that the stud was an integral part of the engine.  Id. (“Dowels of the type in issue perform a fastening or joining function. There is no evidence that they are integral, constituent or component parts necessary to the proper function or operation of an exhaust collector, muffler or engine”).

On the other hand, though, the Low-Pressure Compressor section of the PW4000 aircraft gas turbine engine would be characterized under the aircraft engine parts tariff code as 8411.91.9080. See Classification HQ 962104 (June 11, 1999) (modifying Classification NY C87045 (April 29, 1998) which had been improperly issued based on a mistake of fact about the material).  Similar tariff codes that may be usable for engine parts include:

  • 8411.91.1060 Parts of turbojets or turbopropellers: Cast-iron parts, not advanced beyond cleaning, and machined only for the removal of fins, gates, sprues and risers or to permit location in finishing machinery – for civil aircraft turbine engines.
  • 8411.91.1090 Parts of turbojets or turbopropellers: Cast-iron parts, not advanced beyond cleaning, and machined only for the removal of fins, gates, sprues and risers or to permit location in finishing machinery – for non-civil aircraft turbine engines (including military aircraft engines)

If using one of the 8411.91.10xx tariff codes, the user should be careful of the material from which the part is made. The Customs Service issued several rulings under these codes that had to be corrected because the parts were made from titanium, rather than from cast iron.

Note that the cascades, cascade assemblies, cascade boxes and nacelle cascades for Boeing 737s and 777s (“engine cascades”) would be characterized as aircraft parts under 8803.30.00 (and not under 8411).

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About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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