CLA-2-73:RR:NC:1:118 D87613

Ms. Karin Bogue
Komatsu America International Company
Parts Division
108 N. Industrial Drive
Caller #2101
Ripley, TN 38063

RE: The tariff classification of woodruff keys from Japan.

Dear Ms. Bogue:

In your letter dated February 1, 1999, you requested a tariff classification ruling.

The subject items are described as woodruff keys. A typical key is a half-moon shaped metal wedge which is primarily used to lock pulleys and gears tightly to transmission shafts. Woodruff keys also perform the same locking type function on other applications such as brake pedals, fuel control levers and hydro drive speed levers. These woodruff keys, which are made of steel, are used in machines such as bulldozers and dump trucks. Specifically, they are used in the transmission control linkage of a bulldozer. Most of the imported woodruff keys resemble the sample keys with the exception of size. Some keys are a little larger. The 3 submitted samples are part # 170-14-22691, part # 04010-00416 and part # 04010-00516. Each has a diameter of approximately 5/8". The applicable subheading for the woodruff keys will be 7318.24.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers and similar articles, of iron or steel: non-threaded articles: cotters and cotter pins. The duty rate will be 3.8% ad valorem. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). A copy of this 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 Kathy Campanelli at 212-637-7025.

Sincerely,

Robert B. Swierupski
Director
National Commodity
Specialist Division