CLA-2-84:OT:RR:E:NC:1:102
Mr. Craig M. Schau
Parker Hannifin Corp.
6035 Parkland Blvd.
Cleveland, OH 44124
RE: The tariff classification of a bonded piston seal from Mexico
Dear Mr. Schau:
In your letter dated December 19, 2008 you requested a tariff classification ruling. Descriptive literature was submitted.
The item in question is described as a bonded piston seal. You state that a bonded piston seal is a one-piece piston and seal combination that replaces the traditional piston and seal assembly in the transmission. This piston seal has several applications in automatic transmissions and is designed to convert hydraulic pressure into linear motion. A metal piston moves in and out in a linear fashion in reaction to mechanical pressure from an external source (pump) which pushes the piston into the cylinder.
In particular, you indicate that there are three distinct applications within the transmission in which the conversion of hydraulic pressure into linear motion is used to facilitate vehicle motion, changing gear ratios and/or acting as a brake to prevent component rotation. This conversion is used to facilitate steering in heavy duty equipment, to squeeze a set of clutch plates that transmit torque from the engine to the rear wheels and tighten a band around a drum that locks the drum and prevents rotation. Based on the information you submitted, we find that the bonded piston seals are more specifically provided for as parts of linear acting (cylinders) hydraulic power engines and motors as opposed to parts of transmissions.
The applicable subheading for the bonded piston seals will be 8412.90.9005, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of linear acting hydraulic power engines and motors. The rate of duty is free.
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 T. Brock at (646) 733-3009.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division