CLA-2-84:RR:NC:1:103 D86635
Mr. Mark S. Septimus
EIX Corporation
9009 Western Lake Drive #1410
Jacksonville, FL 32256
RE: The tariff classification of pipette parts from France
Dear Mr. Septimus:
In your letter dated Jan. 7, 1999 you requested a tariff classification ruling.
With your inquiry you submitted samples of several components of a mechanical pipette. A mechanical pipette is a hand held laboratory appliance which utilizes a piston assembly, along with a micrometer which adjusts the piston stroke, to draw and dispense precise volumes of liquids. Your firm intends to import replacement parts for use in the repair of Gilson Pipetman® pipettes. Depending on the model, these pipettes can draw liquid volumes ranging from .1 microliter to 5 milliliters. The parts will be manufactured by Gilson in France, but may be exported from another country. You further stated that neither the parts nor their packaging bear any trademark, patent or copyright information.
The specific parts you inquired about are:
1. Piston assembly - an assembly consisting of a polished stainless steel piston, a plastic plunger, and a neoprene o-ring which allows for the adjustment of the air column for precise volume control.
2. Small spring - a stainless steel spring 3/4 of an inch in length which is used in conjunction with a larger spring to automatically depress the piston assembly after compression.
3. Small spring positioner - a round, tapered plastic ring, open at both ends, which centrally positions the small spring for smooth operation.
4. Filter - a piece of polyethylene approximately 5/8 inch in length which fits into the tip of the pipette shaft. It does not actually filter; instead, it serves to block the liquid while letting air through, thus protecting the shaft from accidental fluid contamination.
The applicable subheading for the piston assembly, small spring positioner and filter will be 8479.90.9595, Harmonized Tariff Schedule of the United States (HTS), which provides for parts of machines and mechanical appliances having individual functions, not specified or included elsewhere (in chapter 84): other: other: other. The rate of duty will be free.
The applicable subheading for the small spring will be 7320.20.5020, HTS, which provides for springs and leaves for springs, of iron or steel: helical springs: other: helical springs, of wire having a cross-sectional dimension of less than 5.1 mm: other. The rate of duty will be 3.9 percent ad valorem.
You may address any questions regarding trademark issues incident to the importation of these goods to the Intellectual Property Rights Branch, U.S. Customs Service, 1300 Pennsylvania Avenue, NW, Washington, DC 20229.
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 Alan Horowitz at 212-637-7027.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division