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NY L81432




December 17, 2004

CLA-2-84:RR:NC:MM:106 L81432

CATEGORY: CLASSIFICATION

TARIFF NO.: 8433.90.1000

Ms. Kimberly Novak
Menlo Worldwide Trade Services
6940 Engle Road
Middleburg, OH 44130

RE: The tariff classification of wheel brake drums for riding lawnmowers from China

Dear Ms. Novak:

In your letter dated December 8, 2004, on behalf of your client Hydro-Gear, you requested a tariff classification ruling. You submitted a sample with your request as well as engineering drawings. Your sample will be returned.

The merchandise at issue is four models of brake drum assemblies. Your product numbers are as follows: 52074, 52071, 52073 and 51286. You state that these assemblies are parts of “zero-turn” lawnmowers, which you describe as riding lawnmowers having the ability to turn in a complete circle while remaining virtually in place. You mention several brand names of “zero-turn” riding lawnmowers on which these assemblies will be used: Ariens, Snapper, Cub Cadet and Bad Boy.

The applicable subheading for the wheel brake drum assemblies will be 8433.90.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts for mowers for lawns, parks or sports grounds. The rate of duty will be free.

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 Patrick Whole at 646-733- 3013.

Sincerely,

Robert B. Swierupski
Director,

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