CLA-2-84:OT:RR:E:NC:N1:102

Ms. Justine Bacani
Mitsubishi Motors North America, Inc.
6400 Katella Avenue
Cypress, CA 90630

RE: The tariff classification of joint kits for automotive power steering systems from Japan

Dear Ms. Bacani:

In your letter dated December 12, 2008 you requested a tariff classification ruling.

The articles in question are described as “joint kits” for automotive powering steering systems. Joint kit MR554368 consists of a carbon steel tube, a rubber O-ring and a shipping plug. The carbon steel tube and O-ring are assembled together with other components to form a conduit for power steering fluid and complete a hydraulic pump assembly.

Joint kit MR272303 consists of a steel valve incorporating four rubber o-rings set into sealing grooves. The primary function of this joint kit is to regulate the pressure of hydraulic fluid within the power steering system.

In your request you suggest that the joint kits are properly classified in heading 8708, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of motor vehicles. However, based on the information provided, we find that the joint kits are specifically provided for in HTSUS headings 8413 and 8412. Further, machines or apparatus of HTSUS heading 8413, or parts thereof, and articles of HTSUS heading 8481 are excluded from HTSUS heading 8708 by Note 1(e) to section XVII of the HTSUS.

The applicable subheading for joint kit MR554368 will be 8413.91.9050, HTSUS, which provides for parts of hydraulic fluid power pumps. The rate of duty is free.

The applicable subheading for joint kit MR272303 will be 8481.20.0050, HTSUS, which provides for other hydraulic valves. The rate of duty will be 2 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Kenneth Brock at (646) 733-3009.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division