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NY H88011




February 7, 2002

CLA-2-87:RR:NC:MM:101 H88011

CATEGORY: CLASSIFICATION

TARIFF NO.: 8708.39.5050, 8708.99.8080

Ms. Elaine E. Loveland
Administrative Analyst
Euclid-Hitachi Heavy Equipment, Inc.
22221 St. Clair Avenue
Cleveland, Ohio 44117-2522

RE: The tariff classification of Steel Tube Assemblies from the United States

Dear Ms. Loveland:

In your letter dated January 22, 2002 you requested a tariff classification ruling.

You submitted technical drawings of steel tube assemblies intended for use on off-highway dumpers for the construction and mining industries. The tube assemblies, when received by you, are ready to be installed in the truck. The tubes are either welded or are seamless construction and are made of carbon/nonalloy steel. The dimensions, outside diameter (OD) and wall thickness are highlighted by you on the submitted engineering drawings, are as follows: 1.50” OD x .095 wall thickness
1.00” OD x .095 wall thickness
1.25” OD x .134 wall thickness.

You further state in your narrative that the tube assemblies are first bent into the required shape. The end fittings are then affixed by welding or brazing to the tube. In some cases the tube is simply fitted with fittings. Also, a tube may be bent and a hole drilled in it to accept a stud, or a tube can be brazed into the original tube.

Your engineer stated that the Steel Tube Assemblies in question are to transport hydraulic fluid in brake and hoist systems from one point to another. These Steel Tube Assemblies are:

Part No. 12616750 Tube Assembly – is part of the Brake System.

Part No. 12616752 Tube Assembly – is part of the Brake system.

Part No. 12582309 Tube Assembly – Goes from the hydraulic tank to a pump to a hoist cylinder to lift the body of the truck.

Part No. 4072052 Tube Spud – is a component of Part No. 12582309.

Part No. 12571915 Tube Assembly – is part of the hydraulic system. It goes from the hydraulic tank to a pump to a hoist cylinder to lift the body of a truck.

The applicable subheading for the Part No. 12616750 Tube Assembly and Part No. 12616752 Tube Assembly will be 8708.39.5050, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Brakes and servo-brakes and parts thereof: Other: For other vehiclesOther.

The applicable subheading for the Part No. 12582309 Tube Assembly, Part No. 4072052 Tube Spud, and Part No. 12571915 Tube Assembly will be 8708.99.8080, 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 and accessories: Other: Other: Other: OtherOther.

If you have any questions regarding the ruling, contact National Import Specialist Robert DeSoucey at 646-733-3008.

Sincerely,

Robert B. Swierupski
Director,

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