CLA-2-39:RR:NC:SP:221 B83923

Mr. Dave Walser
Arthur J. Humphreys Division
Border Brokerage Company, Inc.
P.O. Box 249
Sumas, WA 98295

RE: The tariff classification of the "Speedi-Bleed" brake bleeding kit from Canada.

Dear Mr. Walser:

In your letter dated March 24, 1997, on behalf of Abbotsford Stop 'N Shop, Canada, you requested a tariff classification ruling.

The Speedi-Bleed Pro Kit is used to pressure bleed air from an automotive hydraulic brake system. The kit includes a hose, a bottle, four adapters and three tension straps. The hose is made of unreinforced polyvinyl chloride plastic and incorporates a pressure regulator. One end of the hose has a fitting by which it may be connected to the tire valve. The other end of the hose is connected to a cap which screws onto the plastic bottle. Also attached to the bottle cap is a plastic tube with a fitting at the end. The adapters are designed to connect this plastic tube to different types of master cylinders. The tension straps are designed to secure the adapter to the master cylinder reservoir. In the process of bleeding the brakes, the bottle is filled with brake fluid, the hose is attached to a tire, and the tube is attached to the adapter on the master cylinder. Air from the tire supplies the operating pressure to bleed the brake. The components in this kit constitute a set, with the essential character imparted by the hose with attached pressure regulator.

The applicable subheading for the Speedi-Bleed brake bleeding kit will be 3917.33.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for tubes, pipes and hoses and fittings therefor, of plastics...other, not reinforced or otherwise combined with other materials, with fittings. The general rate of duty will be 3.1 percent 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 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 Joan Mazzola at 212-466-5580.

Sincerely,

Gwenn Klein Kirschner
Chief, Special Products Branch
National Commodity
Specialist Division