CLA-2-84:S:N:N3:102 898678

Mr. John Wolper
Kaerntner Group, Inc.
P.O. Box 771
Kimberton, PA 19442

RE: The tariff classification of a hydraulic power unit from Austria

Dear Mr. Wolper:

In your letter dated May 31, 1994 you requested a tariff classification ruling. The items at issue in this request are the Kahlbacher Hydraulic Units # IV GRE 2/K-2S and GRE 3/K- 2S. According to the literature supplied, these units are designed for mounting onto trucks and similar vehicles for the purpose of providing hydraulic power for the operation of snow plows and similar equipment. The system is imported in two main sections that consist of the following: a rotary hydraulic pump mounted onto a frame and driven by a pulley powered off of the truck engine; and a distribution module, pre-configured onto a heavy steel mounting plate, which contains solenoid control valves, oil filters and quick-connect couplings for attaching hydraulic hoses. A driver-operated control panel, which will be installed onto the dashboard, is connected to this assembly. The main difference between the two models is the number of functions that each can support and the number of hydraulic connections available. While the system consists of a number of components, we consider them to form a functional entirety, the primary element of which is the hydraulic power pump.

The applicable subheading for the Kahlbacher Hydraulic Units will be 8413.60.0040, Harmonized Tariff Schedule of the United States (HTS), which provides for other rotary positive displacement hydraulic fluid power pumps. The rate of duty will be 3 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