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NY D82829




October 30, 1998

CLA-2-84:RR:NC:1:102 D82829

CATEGORY: CLASSIFICATION

TARIFF NO.: 8484.20.0000, 8484.20.0000, 8483.90.5000, 8505.20.0000

Mr. Dana L. Trout
Trans-Trade, Inc.
P.O. Box 612369
DFW Airport, TX 75261

RE: The tariff classification of compressor parts from Japan

Dear Mr. Trout:

In your letter dated September 18, 1998 you requested a tariff classification ruling on behalf of Sanden International

The articles in question are a cylinder head with gasket, part 7433-9630, a lip seal, part 7703-6150, a clutch assembly with accessory kit, part 4605-9930, an accessory kit, part 4605-9800, and an O-gear, part 7905-0290. Samples and technical drawings were submitted.

The cylinder head and gasket are parts of an air conditioning compressor which attach to the compressor's cylinder block. The head and gasket are imported and sold together in retail packaging. The lip seal is a mechanical seal used to contain gases within the compressor. The O-gear is an oscillating gear which is part of a compressor's internal gearing.

The clutch assembly with accessory kit is a magnetic clutch assembly with all the parts necessary to mount the clutch assembly within the compressor. The accessory kit contains the mounting components, which include snap rings, shims, fasteners, wire and a shaft key.

The accessory kit included with the clutch assembly may be purchased separately as a repair kit when a complete clutch assembly is not needed. The parts contained in the accessory kit are imported and sold together in retail packaging. We find that the shaft key, which ensures the transmission of torque from the clutch assembly to the compressor's piston assembly, gives the accessory kit its essential character.

The applicable subheading for the lip seal will be 8484.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for mechanical seals. The rate of duty will be 4.3 percent ad valorem.

The applicable subheading for the clutch assembly with accessory kit, when presented together, will be 8505.20.0000, HTSUS, which provides for electromagnetic couplings, clutches and brakes. The rate of duty will be 3.3 percent ad valorem.

The applicable subheading for the O-gear, will be 8483.90.5000, HTSUS, which provides for parts of gearing, gear boxes and other speed changers. The rate of duty will be 2.5 percent ad valorem.

The applicable subheading for the cylinder head with gasket and the accessory kit, when presented separately, will be 8414.90.4040, HTSUS, which provides for other parts of refrigerating and air conditioning compressors. The rate of duty will be 0.7 percent ad valorem.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR 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 Kenneth T. Brock at 212-466-5493.

Sincerely,

Robert B. Swierupski
Director,

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