CLA-2-84:RR:NC:1:102 F80160

Mr. Robert J. Resetar
Porsche Cars North America, Inc.
980 Hammond Drive (Suite 1000)
Atlanta, GA 30328

RE: The tariff classification of an ignition vacuum timing unit from Germany

Dear Mr. Resetar:

In your letter dated November 23, 1999 you requested a classification ruling on behalf of Porsche Cars North America.

The item in question is an ignition vacuum timing unit for an automotive engine. The timing unit is a component that mounts on the side of an ignition distributor and is an actuator used to advance or retard ignition timing in response to the intake manifold vacuum produced by the engine. Descriptive information and a sample were submitted.

The unit consists of a metal housing with a vacuum line port and an internal rubber diaphragm connected to a metal lever. The lever passes through an opening in the housing and connects to the ignition distributor. When a vacuum line from the intake manifold is connected to the timing unit, the rubber diaphragm expands and contracts in response to vacuum pressure. The diaphragm converts any change in vacuum pressure into a mechanical force and imparts linear motion to the lever. The linear motion of the lever is then used to adjust the distributor and advance or retard the ignition timing.

The applicable subheading for the ignition vacuum timing unit will be 8412.39.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other pneumatic power engines and motors. The rate of duty is free.

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 212-637-7026.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division