Import Classification 101: Introduction to Harmonized Tariff Codes (Part 2 of 3)

How are most commercial airplane parts supposed to be categorized under the Harmonized Tariff Schedule?  Many commercial airplane parts will be characterized as “8803.10.00.30.”  In today’s article we will focus on what this string of numbers really means.

This is the second in a three-part series of articles discussing import into the United States of aircraft parts. Yesterday, we explained that classifications of goods is based upon the U.S. Harmonized Tariff Schedule (USHTS). Today we will look more closely at the basic harmonized tariff codes applicable to aircraft parts.

U.S. import law applies to goods that enter the customs territory of the United States. Each such part must be classified correctly in order to assess the tariff status of the part. Most aircraft parts will fall within the scope of the Agreement on Trade in Civil Aircraft, which provides for the duty-free entry of civil aircraft and their parts into signatory nations (including the United States). But there are significant exceptions to this provision, and there is a significant minority of aircraft parts that will not be classified under the “aircraft parts” provisions of this Agreement [more on this tomorrow!].

Most aircraft parts are categorized under Chapter 88 of the Harmonized Tariff Code, and the most commonly used code will begin with 8803 (which is for parts). The additional numbers after the initial “8803” help to specify exactly what sort of aircraft parts they are. Civil aircraft propeller parts are characterized as 8803.10.00.30. Civil aircraft undercarriage parts are 8803.20.00.30 if they are intended for aircraft used by anyone other than the Department of Defense or the Coast Guard (the numbers would change if you altered any of these particulars).

Seeing a pattern to these numbers? The first set of digits (8803) indicates that it is an aircraft part. If the second sequence is “10” then it is a rotor or propeller part. If it is “20” then it is an undercarriage part. If it is a “30” then it is an “other” part from an airplane or helicopter.

For these particular subheadings, the third sequence will always be “00” but in other headings and subheadings, you can have different third sequence numbers that help to further distinguish different goods. The fourth sequence helps to further distinguish the nature of the parts, so for example in these subheadings a fourth sequence of “15” usually means the part is for use in a civil aircraft and civil aircraft is used by the Department of Defense or the United States Coast Guard. A fourth sequence of “30” usually means the part is for use in a civil aircraft that is NOT used by the Department of Defense or the United States Coast Guard.

As you can see, most civil aircraft parts imported by U.S. repair stations will be described as by harmonized tariff code 8803.30.00.30. Civil aircraft parts classified as 8803.30.00.30 may usually be entered into the U.S. on a duty free basis.

But, unfortunately, import classification of aircraft parts is not always this simple. There are many aircraft parts that fit into listed exceptions, and these parts are characterized under different tariff codes. Some of these tariff codes require the payment of import duties (the parts are not treated as duty-free under the Agreement on Trade in Civil Aircraft. On Monday morning, we examine the exceptions.

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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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