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NY K89367




September 30, 2004

CLA-2-73:RR:NC:MM:101 K89367

CATEGORY: CLASSIFICATION

TARIFF NO.: 7320.90.5020, 8302.30.3060, 8708.39.5050, 7320.90.5060

Mr. Dennis C. Paulaskas
Asian Pacific Products, Inc.
3001 North Kings Highway
Myrtle Beach, South Carolina 29579

RE: The tariff classification of automotive brake components from China

Dear Mr. Paulaskas:

In your letter dated August 31, 2004 you requested a tariff classification ruling. You have provided samples of each product.

The first item is described as a brake return spring for automotive aftermarket applications. This is also described on drawing number 52357A . You state that the commercial designation is “Spring – drum return.” The material is hard drawn Spring Wire (ASTM A227).

The second item is described as Brake Pad Clip for automotive aftermarket applications. This is also described on drawing number 5760C. You state that the commercial designation is “Pad Clip.” The material is SAE 30301 Stainless Steel.

The third item is described as a Nut-Self Adjuster for automotive aftermarket brake applications. This is also described on drawing number 54110B. You state that the commercial designation is “Nut-Self Adjuster.” The material is 1018-1030 Low carbon steel.

The fourth item is a brake pad clip for automotive aftermarket applications. This is also described on drawing number 10520E. You state that the commercial designation is “Pad Clip.” The material is SAE 30301 Stainless Steel.

The fifth item is a Self-Adjuster Tip for automotive aftermarket applications. This is also described on drawing number 54001B. You state that the commercial designation is “Self-Adjuster Tip.” The material is 1018-1030 Low Carbon Steel.

The sixth item is a Brake Key Spring for automotive aftermarket applications. This is also described on drawing number 4299B. You state that the commercial designation is “Key Spring.” The material is .090 Cold Rolled Steel 1070.

The applicable subheading for the Brake Return Spring (Spring-Drum Return) will be 7320.90.5020, Harmonized Tariff Schedule of the United States (HTS), which provides for Springs and leaves for springs, of iron or steel: Other: Other: of wire: Other. The rate of duty will be 2.9 percent.

The applicable subheading for the Brake Pad Clip (Pad Clip) will be 8302.30.3060, Harmonized Tariff Schedule of the United States (HTS), which provides for Base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like: base metal hat racks, hat-pegs, brackets and similar fixtures: castors with mountings of base metal: automatic door closers of base metal; and base metal parts thereof: Other mountings, fittings and similar articles suitable for motor vehicles; and parts thereof: of iron or steel, of aluminum or of zinc: Other. The rate of duty will be 2 percent.

The applicable subheading for the Nut-Self Adjuster (Nut-Self Adjuster) 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 vehicles: Other. The rate of duty will be 2.5 percent.

The applicable subheading for the Brake Pad Clip (Pad Clip) will be 8302.30.3060, Harmonized Tariff Schedule of the United States (HTS), which provides for Base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like: base metal hat racks, hat-pegs, brackets and similar fixtures: castors with mountings of base metal: automatic door closers of base metal; and base metal parts thereof: Other mountings, fittings and similar articles suitable for motor vehicles; and parts thereof: of iron or steel, of aluminum or of zinc: Other. The rate of duty will be 2 percent.

The applicable subheading for the Self-Adjuster (Self-Adjuster Tip) 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 vehicles: Other. The rate of duty will be 2.5 percent.

The applicable subheading for the Brake Key Spring (Key Spring) will be 7320.90.5060, Harmonized Tariff Schedule of the United States (HTS), which provides for Springs and leaves for springs, of iron or steel: Other: Other: Other. The rate of duty will be 2.9 percent.

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 646-733-3008.

Sincerely,

Robert B. Swierupski
Director,

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