CLA-2-84:OT:RR:NC:N1:102
Ms. Jini Koh
Crowell & Moring LLC
1001 Pennsylvania Avenue, NW
Washington, DC 20004
RE: The tariff classification of a water pump seal set from Japan.
Dear Ms. Koh:
In your letter dated October 30, 2013 you requested a tariff classification ruling on behalf of your client, Aisin Holdings of America, Inc. A representative sample was submitted with your request and will be retained by this office.
The product under consideration, referred to as part number 213180, is described as a water pump seal set. You indicate that this seal set is specifically designed for and solely used in an automobile’s water pump to prevent leakage of coolant from the shaft area out of the pump. It consists of a rubber cup gasket and bellows, a silicon carbide mating ring, a carbon graphite seal ring and a stainless steel spring, coil cartridge and sleeve. The primary sealing function occurs when the seal ring and the mating ring come in contact with each other.
You suggest classification of the seal set in subheading 8413.91.9010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for pumps for liquids, whether or not fitted with a measuring device; liquid elevators; parts thereof, parts, of pumps, other, of subheading 8413.30.90. However, based on the information provided, this office finds that the subject item is a mechanical seal. Mechanical seals are specifically provided for in heading 8484, HTSUS.
Note 2(a) to Section XVI of the HTSUS provides that parts which are goods included in any of the headings of Chapter 84 are to be classified in their respective headings. Although the mechanical seal is, prima facie, a part of the pump in which it is used, because the seal is a good of heading 8484, HTSUS, it cannot be classified as a part of a pump in heading 8413, HTSUS. Accordingly, the mechanical seal falls to be classified in heading 8484, HTSUS.
The applicable subheading for the water pump seal set will be 8484.20.0000, HTSUS, which provides for gaskets and similar joints of metal sheeting combined with other material or of two or more layers of metal; sets or assortments of gaskets and similar joints, dissimilar in composition, put up in pouches, envelopes or similar packings; mechanical seals. The rate of duty will be 3.9 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 Patricia O’Donnell at (646) 733-3011.
Sincerely,
Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division