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NY C81351

November 12, 1997

CLA-2-88:RR:NC:MM:106 C81351


TARIFF NO.: 8803.30.0010

Mr. Edward G. Doll
Sikorsky Aircraft Corporation
6900 Main Street
P.O. Box 9729
Stratford, Connecticut 06497-9129

RE: The tariff classification of helicopter kits from various countries.

Dear Mr. Doll:

In your letter dated October 30, 1997, you requested a tariff classification ruling. You submitted descriptive literature with your request.

You state that you intend to import various "kits" for the Sikorsky S-92 commercial helicopter. These kits, or aircraft sections, will be imported as 7 modular sections. The individual sections, imported in kit form, are described as follows:

Cabin - the cabin, manufactured in Japan, consists of structural hardware, skin of the cabin section and a number of supports, assemblies and fittings for equipment to be installed in the helicopter.

Cockpit - the cockpit, manufactured in Taiwan, consists of structural hardware and skin of the cockpit section and a number of fittings, brackets and racks for instrumentation and avionic equipment.

ATT - (Aft Transition Tail Cone) - the ATT, manufactured in Spain, is that section of the helicopter that is the transition between the cabin and the tail cone (rear end of the cabin). The ATT consists of structural assemblies, fairings and fittings.

Interiors - the interior, manufactured in Spain, consists of interior panels, furnishings and supports, but does not include any seats.

Sponsons - the sponsons on each side of the helicopter, manufactured in Brazil, house the fuel cells for the helicopter. Component parts of the sponson kits include structural assembled hardware for installation of the fuel cells.

Stabilizer - the stabilizer, manufactured in Spain, provides horizontal stability to the helicopter and consists of structural assembly components.

Tail Cone - the tail cone, manufactured in China, is the end section of the helicopter consisting of structural hardware and assemblies.

All of these kits are comprised of a number of individual components and various materials. Each kit is an incomplete or unfinished section and will be imported in an unassembled condition. However, it is the opinion of this office that each kit has the essential character of the finished or complete aircraft section outlined above. All of these section kits will be assembled by Sikorsky into the completed helicopter at their facility in Stratford, Connecticut. Final assembly at these facilities will include avionics, engines, subsystems, seats, and entail stringing of wire, cables and other connecting material to complete the final helicopter.

The applicable subheading for the helicopter kits will be 8803.30.0010, Harmonized Tariff Schedule of the United States (HTS), which provides for Other parts of airplanes or helicopters... For use in civil aircraft. The rate of duty will be free.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Patrick J. Wholey at 212-466-5668.


Robert B. Swierupski

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