CLA-2-98:RR:NC:2:227 G82169

Mr. Rudy Pina
William F. Joffrey, Inc.
Customs Brokers
P.O. Box 698
Nogales, AZ 85628-0698

RE: The tariff classification of ceramic valve sleeves and pistons exported from the United States to Mexico for further processing.

Dear Mr. Pina:

In your letter dated August 29, 2000, on behalf of CoorsTek, you requested a tariff classification ruling.

The articles at issue are ceramic beverage valve components. The components consist of valve sleeves and pistons of alumina that are manufactured to a semi-finished state in the United States and then sent to a maquiladora in Mexico where they are ground and polished to their finished dimensions. The semi-finished components shipped to Mexico are incomplete for their intended use. The further processing in Mexico constitutes an operation that is performed as a matter of course in the manufacture of finished valve sleeves and pistons. When the processing in Mexico is completed, the finished components will be returned to the United States where they are to be incorporated into flow mechanisms for use in beverage dispenser machines.

You claim that this merchandise is properly classified under subheading 6903.20.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other refractory ceramic goods…containing by weight more than 50 percent of alumina or of a mixture or compound of alumina and of silica. However, an item to be classified as refractory goods in heading 6903, (HTS), must not only be capable of resisting high temperatures but must also be designed for high temperature work. Since the ceramic sleeves and pistons are not designed for high temperature work, they cannot be classified as refractory articles under subheading 6903.20.0000, HTS.

The applicable subheading for the ceramic valve sleeves and pistons will be 6909.11.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for ceramic wares for laboratory, chemical or other technical uses; machinery parts of porcelain or china. The rate of duty will be 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 George Kalkines at 212-637-7073.


Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division