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

Ms. Nicole M. Jenkins
Crowell & Moring LLP
1001 Pennsylvania Avenue NW
Washington, DC 20004

RE: The tariff classification of master cylinder bodies from Japan

Dear Ms. Jenkins:

In your letter dated July 1, 2010 you requested a tariff classification ruling on behalf of your client, Aisin Holdings of America, Inc.

The articles in question are described as master cylinder bodies, part numbers 132111-50170, 132111-80200 and 132111-80140-40. You indicate in your request that each of the identified parts are functionally identical and have included a schematic drawing of part number 132111-50170 and a photograph of part number 132111-80200.

The master cylinder bodies are made of aluminum alloy and contain multiple ports for brake fluid reservoir connections brake lines and a single bore that is separated into two chambers by a primary and a secondary piston. You state that these parts are incorporated into an automobile’s brake booster, and their primary function is to generate hydraulic pressure and route brake fluid through the brake lines which enables the vehicle to brake.

The brake booster is comprised of several components, including a hydraulic booster, an accumulator and a master cylinder. When the brake pedal is depressed, an electric motor within the booster drives a piston pump to discharge hydraulic fluid into an accumulator. The increased hydraulic pressure within the accumulator is then used to drive the primary and secondary pistons with the master cylinder which forces hydraulic fluid into the brake lines to actuate the vehicle’s brakes. Brake booster assemblies were previously ruled upon in New York Ruling N014493 as other reciprocating positive displacement pumps for hydraulic fluid in subheading 8413.50.0080, Harmonized Tariff Schedule of the United States (HTSUS).

Based on the information submitted, the subject master cylinder bodies are integral components of the mechanism used in positive displacement piston pumps to provide fluid power in hydraulic systems.

The applicable subheading for the master cylinder bodies will be 8413.91.9050, HTSUS, which provides for parts of hydraulic fluid power pumps. 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