CLA-2-84:S:N:N1:102 853717
Mr. Dale Munn
Racine Fluid Power, Inc.
7505 Durand Ave.
Racine, Wisconsin 53406
RE: The tariff classification of combination filter-regulator-
lubricator (FRL) from France
Dear Mr. Munn:
In your letter dated June 18, 1990 you requested a tariff
classification ruling.
The item in question is a combination air filter, pressure
regulator, and pneumatic lubricator. Since unregulated
compressed air often contains water vapor and harmful particles
that could damage a system, a FRL is a common accessory installed
in the pneumatic line. The filter removes the contaminants and
water vapor; the regulator controls the downstream air pressure,
and the lubricator injects a fine oil mist into the air supply by
means of the venturi principle. The three components are pre-
assembled and sold as an entirety. Based on the literature
provided it appears that the function of the filter and regulator
are always required in a pneumatic system, and that the
lubrication function is required a significant amount of time.
In that we would view the FRL as a composite article, for
classification purposes, and one in which there is no one
essential function, we would revert to Rule 3 (c) of the General
Rules of Interpretation of the Harmonized Tariff Schedules. In
brief summary, Rule 3(c) states that such an article would be
classified in that HTS provision which appears last among all of
the eligible competing provisions.
The applicable subheading for the FRL will be 8481.10.0000,
Harmonized Tariff Schedule of the United States (HTS), which
provides for pressure-reducing valves. The rate of duty will be
3.7 percent ad valorem.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport