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NY 898929




July 6, 1994

CLA-2-84:S:N:N1:103 898929

CATEGORY: CLASSIFICATION

TARIFF NO.: 8431.31.0060

Mr. Tom Cleveland
Tricoastal Industries, Inc.
535 Connecticut Avenue
Norwalk, Connecticut 06854

RE: The tariff classification of elevator guide rails from Brazil, China, Germany, Italy, Korea or Taiwan

Dear Mr. Cleveland:

In your letter dated June 1, 1994, you requested a tariff classification ruling.

Elevator guide rails are T-shaped rails used to guide elevator cars as they travel up and down the elevator shaftway. The merchandise in question will be imported in two conditions - unfinished and finished.

In the finished condition, a hot rolled "T" section of ordinary low carbon structural steel has undergone processing prior to importation to produce an article to be solely used as an elevator guide rail. Processing includes machining operations such as straightening, planing, and milling and painting to prevent rust. The rails weigh from 8 to 30 pounds per foot. Lengths vary from 10 to 20 feet depending upon customer specifications but are generally 16 feet for most applications.

The applicable subheading for the finished elevator guide rails will be 8431.31.0060, Harmonized Tariff Schedule of the United States (HTS), which provides for parts suitable for use solely or principally with passenger or freight elevators, other than continuous action elevators. The duty rate will be 2 percent ad valorem.

Articles classifiable under subheading 8431.31.0060, HTS, which are products of Brazil are entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations.

Your inquiry does not provide enough information for us to give a classification ruling on the unfinished sections. Your request for a classification ruling should include a step-by-step description of the manufacturing operations performed in Brazil and in the United States. Submit detailed data on man hours expanded, labor costs and additional component (if any) costs incurred.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director

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