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NY 894591




February 22, 1994

CLA-2-87:S:N:N1:101-894591

CATEGORY: CLASSIFICATION

TARIFF NO.: 8708.99.7060

Mr. Roger M. Golden
Fenwick & West
1920 N Street, NW
Suite 650
Washington, DC 20036

RE: The tariff classification of shock absorber components from Germany

Dear Mr. Golden:

In your letter dated January 28, 1994, on behalf of Sachs Automotive of America (SAA), Troy, MI, you requested a tariff classification ruling. You have submitted 5 samples of the products, which are as follows:.

SAA part no. 00-1710-489-015 is called a Scheibe (translation: washer). This part is made of spring steel. It is used to regulate fluid flow in the base valve of automotive shock absorbers during the compression cycle. The circular shaped item (with three notches) has an inside diameter (hole portion) of approximately 3/16 inches, and an outside diameter of approximately 3/4 inches.

SAA part no.s 00-1710-557-003, 00-1710-558-002, 00-1710-559-019 and 00-1710-561-000 are called a Scheibe (translation: washer). These parts are made of spring steel. They are used to regulate fluid flow in the automotive piston assembly, primarily during the extension cycle.

Part no. 00-1710-557-003 is circular in shape (with four notches). It has an inside diameter (hole) of approximately 3/8 inches and an outside diameter of approximately one inch.

Part no. 00-1710-558-002 is circular in shape. It has an inside diameter (hole) of approximately 3/8 inches and an outside diameter of approximately 7/8 inches.

Part no. 00-1710-559-019 is circular in shape. It has an inside diameter of approximately 3/8 inches and an outside diameter of approximately 1/2 inches.

Part no. 00-1710-561-000 is circular in shape (it has an inner and outer ring). This item has an outside diameter of approximately 1-1/8 inches.

The shock absorber itself is attached to the motor vehicle in such a way that, as the wheel moves up and down, the shock absorber shortens and lengthens, or telescopes and extends. Since the shock absorber imposes a restraint on this movement, excessive wheel and spring movements as well as spring oscillations are prevented. The imported products are part of the shock absorber assembly.

Washers are usually defined as small, thin discs with in a hole in the center; they are placed between the nut and one of the parts to be fixed to protect the latter. The subject items do not meet the definition of subheading 7318.22.0000 (the provision for other washers of iron or steel) because they do not appear to be suitable to be placed between the nut and one of the parts to be fixed.

The applicable subheading for the SAA part no.s 00-1710-489-015, 00-1710-557-003, 00-1710-558-002, 00-1710-559-019 and 00-1710-561-000 (washers) will be 8708.99.7060, Harmonized Tariff Schedule of the United States (HTS), which provides for parts and accessories of the motor vehicles of headings 8701 to 8705: other: parts for suspension systems. The rate of duty will be 3.1 percent ad valorem.

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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