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NY N019900

December 4, 2007



TARIFF NO.: 8906.90.0090

Mr. Dan Kromat
Manager, Customs Compliance
KSI Corporation
851 Traeger Ave., #200
San Bruno, CA 94066

RE: The tariff classification of a remotely operated submersible vessel.

Dear Mr. Kromat:

In your letter dated November 19, 2007 you requested a tariff classification ruling. You included a sales brochure for the Quantum submersible vessel and technical information for the Monterey Bay Research Institute’s (MBARI) Tiburon II submersible vessel. You have stated in a follow up email on November 29, 2007, that the specifications for both vessels are the same.

The merchandise at issue is referred to as the Quantum Construction Class Work ROV (remote operated vessel) which is imported with its control room and peripherals for operation. The Quantum can be designed to perform various tasks including construction and military operations. You have stated that this is being imported to perform scientific tasks for the MBARI. The Quantum measures approximately 3260 mm in length, 1950 mm wide and 1756 mm high. It is propelled by seven onboard hydraulic thrusters. The vessel is controlled remotely by computer and joysticks from the control room through an umbilical cable. The Quantum has a depth rating of 4000 meters. Scientific instruments may be attached and exchanged form the integral sub-frame of the Quantum as needed.

The applicable subheading for the Quantum Construction Class Work ROV will be 8906.90.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other vessels: other, other. The general rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Mark Palasek at 646-733-3013.


Robert B. Swierupski

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