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NY C85167





April 2, 1998

CLA-2-85:RR:NC:MM:101 C85167

CATEGORY: CLASSIFICATION

TARIFF NO.: 8545.20.0000; 8483.90.5000; 8511.90.6040; 8547.20.0000

Ms. Barbara Dawley
Meeks & Sheppard
330 Madison Ave.
39th Floor
New York, NY 10017

RE: The tariff classification of automotive starter kits

Dear Ms. Dawley:

In your letter dated March 6, 1998, you requested a tariff classification ruling.

The first item (shown below) is a copper-colored, mallet-shaped piece of metal comprised of a Starter Brush (Part# 028531-5670) and a Terminal Plate (Part# 028175-0571); it measures 2¬"L X 1"W. The starter brush acts as a conduit for electricity and is used as a replacement brush in Starter Assemblies. These parts, when attached together, are imported as Starter Kit #028099-3550.

The applicable subheading for the Starter Kit # 028099-3550 will be 8545.20.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for . . . carbon brushes . . . : Brushes. The rate of duty will be 0.7% ad valorem.

The second item (shown below) consists of a star-shaped piece of gray metal with a hole through it's middle called a Starter Pinion (Part# 028371-2091) measuring 4«" in circumference; a six-sided, circular-shaped, gold-colored piece of metal with a hole in it's middle called a Pinion Stop Nut (Part# 028021-0230) measuring 1«" in circumference; a gray, circular piece of metal with an inner lip and a hole in it's center called a Snap Retainer (Part# 028327-0140) measuring 2«" in circumference; a dark gray-colored, circular piece of metal with inner teeth called a Snap Ring (Part# 949072-1080) measuring 2¬" in circumference and a Compression Coil Spring (Part# 949170-3371) measuring 2" in circumference. These parts are imported together as Starter Kit #028099-3880.

The applicable subheading for the Starter Kit #028099-3380 will be 8483.90.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for . . . gears and gearing . . . : Parts: Parts of gearing, gear boxes and other speed changers. The rate of duty will be 2.5% ad valorem.

The third item consists of a Clutch Sub-assembly (Part# 028300-6970) [diagram shown below], a Pinion Stop Nut (Part# 028021-0230), a Starter Pinion (Part# 028371-6480), a Snap Retainer (Part# 028327-0140), a Shaft (Part# 028381-0150), a Snap Ring (Part# 949072-1080), two Compression Coil Springs (Parts# 949170-3371) and a Compression Coil Ring (Part# 949170-4260) . These parts are imported together as Starter Kit #028099-6440.

The applicable subheading for Starter Kit #028099-6440 will be 8511.90.6040, Harmonized Tariff Schedule of the United States (HTS), which provides for . . . starting equipment . . . for engines . . . : Parts: Other Parts: Other. The rate of duty will be 2.6% ad valorem.

The fourth item (partially shown at top of next page) consists of a black piece of circular, hard plastic with a hole in it's center and an outer lip measuring 3" in circumference called a Plastic Bushing (Part# 053449-0110); a black, table-shaped piece of hard plastic with a hole in it's center measuring ¬"L X "W called a Plastic Bushing (Part#053449-0121); an L-shaped piece of copper with a hole through one side measuring 1 "L X "W called a Copper Contact Plate (Part# 053513-0241); a circular, steel washer with two, edged sides (Part# 128952-0090) measuring 1«" in circumference; a copper bolt (Part# 949044-1312) measuring 1" in length; a steel, hexagonal nut (Part# 949050-2820) and a black, soft rubber O-Ring (Part# 949140-2100) measuring 1" in circumference. All these parts are imported together as Starter Kit #028099-3010 and serve as replacement parts for the magnetic switch in a vehicle's starter.

The applicable subheading for the Starter Kit #028099-3010 will be 8547.20.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for Insulated fittings for electrical machines . . . : Insulated fittings of plastics. The rate of duty will be 0.7% ad valorem.

The last item (shown below) consists of a black, circular piece of hard plastic with a hole in it's center and an outer lip measuring ¬"L and 3«" in circumference called a Plastic Bushing (Part# 053449-0082); a brown, table-shaped, piece of hard plastic with a hole in it's center and an outer lip measuring "L X 3¬"W called a Resin Bushing (Part# 053449-0150); an L-shaped piece of copper with a hole in one side measuring 1 "L X "W called a Copper Contact Plate (Part# 053513-0261); a circular, steel washer with two edged sides (Part# 949017-1290) measuring 2" in circumference; a copper bolt (Part# 949044-1912) measuring 1¬" in length and a steel, hexagonal nut (Part# 949050-3670) measuring 2¬" in circumference. All these parts are imported together as Starter Kit #028099-3160.

The applicable subheading for Starter Kit #028099-3160 will be 8547.20.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for Insulated fittings for electrical machines . . . : Insulated fittings of plastics. The rate of duty will be 0.7% ad valorem.

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 Robert DeSoucey at 212-466-5667.

Sincerely,

Robert B. Swierupski

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