CLA-2-84:RR:NC:1:103 H81284
Mr. Craig M. Schau
Emery Customs Brokers
6940A Engle Road
Middleburg Heights, OH 44130
RE: The tariff classification of a mechanical seal and parts thereof from Japan
Dear Mr. Schau:
In your letter dated May 17, 2001 on behalf of Freudenberg-NOK you requested a tariff classification ruling.
With your inquiry you submitted a sample of the complete mechanical seal, as well as samples of two seal rings and a casing which are components of the seal. The seal, designated as part number 07904043800, basically consists of a spring, spring holder, sleeve, bellows, cup gasket, ceramic and graphite sealing rings, cartridge, and driving band. The seal is intended for use in an automobile water pump, and is designed to prevent coolant from leaking around the pump shaft as it enters the pump body. The tension exerted by the spring against the ceramic and graphite seal rings creates a mechanical seal while permitting high speed and slight off-axis rotation of the pump shaft.
The applicable subheading for the complete mechanical seal will be 8484.20.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for mechanical seals. The duty rate will be 3.9 percent ad valorem.
In your letter you stated that the sintered carbide (graphite) sealing ring, the silicon carbide (ceramic) sealing ring, and the stainless steel case used in this mechanical seal are separately imported and then assembled domestically by your client. You suggested that these parts, when imported separately, should be classified in subheading 8484.90.0000, HTS. However, since heading 8484 does not provide for parts of mechanical seals or any of the other goods classifiable in that heading, we are unable to concur with your assertion.
The mechanical seal will be used as a part of an automobile water pump. Accordingly, the applicable subheading for the stainless steel case, imported separately, will be 8413.91.9010, HTS, which provides for parts of pumps of subheading 8413.30.90 (fuel, lubricating or cooling medium pumps for internal combustion piston engines: other). The rate of duty will be free.
Notes 1(a) and 1(b) to chapter 84 exclude graphite and ceramic articles from classification in any heading of chapter 84. The applicable subheading for the sintered carbide (graphite) seal ring, imported separately, will be 6815.10.0000, HTS, which provides for nonelectrical articles of graphite or other carbon. The rate of duty will again be free.
Your inquiry does not provide enough information for us to give a classification ruling on the silicon carbide (ceramic) seal ring when imported separately. Your request for a classification ruling should include information as to the type of ceramic (i.e., porcelain or stoneware) of which the seal ring is composed. In addition, you should provide an analysis from a certified laboratory indicating whether this article has a hardness equivalent to 9 or more on the Mohs scale. When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.
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 Alan Horowitz at 212-637-7027.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division