CLA-2-84:S:N:N1:102 853745
Ms. Elizabeth K. Zugschwert
Herman Ludwig Inc.
28969 Highlands Road
Romulus, Michigan 48174
RE: The tariff classification of hydraulic vane pumps, fluid
reservoirs and steering gears from Brazil
Dear Ms. Zugschwert:
In your letter dated June 12, 1990, on behalf of your client
ZF of North America, you requested a tariff classification
ruling.
Your letter describes three main components of a hydraulic
steering system used on vehicle class 6, 7, & 8 heavy duty
trucks. The components, which are imported separately, are
hydraulic pumps, hydraulic fluid reservoirs, and hydraulically-
operated steering gears. The ZF models 7673, 7674, and 7677 are
rotary positive displacement vane pumps which couple directly to
the vehicle engine and provide the necessary hydraulic power for
the steering mechanism. The models 7632 and 7636 oil tanks are
made of heat resistant plastic and contain both a dirt particle
filter and internal check valve. In addition, model 7632
includes an electric oil level switch. Their principal function
is to act as a hydraulic fluid reservoir for the above pumps. ZF
Servocom models 8095, 8097 & 8098 steering gears are compact
"ball and nut" power steering units. By applying rotational
torque from the steering wheel, a worm gear is turned and, under
hydraulic power assistance, a piston section is moved, causing
the road wheels to also turn.
The applicable subheading for the hydraulic vane pumps will
be 8413.60.0020, Harmonized Tariff Schedule of the United States
(HTS), which provides for other rotary, positive displacement,
vane type hydraulic fluid power pumps . The duty rate will be 3
percent ad valorem.
The applicable subheading for the hydraulic reservoirs will
be 8708.99.5090, HTS, which provides for other parts of motor
vehicles of headings 8701 to 8705, other, other. The duty rate
will be 3.1 percent ad valorem.
The three Servocom hydraulic steering gear models will be
classifiable under the provision for steering wheels, steering
columns and steering boxes for vehicles other than agricultural
tractors, HTS subheading 8708.94.5000. The duty rate will be 3.1
percent ad valorem.
Articles classifiable under subheadings 8413.60.0020 and
8708.94.5000, HTS, which are products of Brazil are entitled to
duty free treatment under the Generalized System of Preferences
(GSP) upon compliance with all applicable regulations.
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