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NY L82106





January 24, 2005

CLA-2-73:RR:NC:N1:118 L82106

CATEGORY: CLASSIFICATION

TARIFF NO.: 7320.20.1000

Ms. Natascha Northrup
ArvinMeritor, Inc.
100 Westwood Place, Suite 200
Brentwood, TN 37027

RE: The tariff classification of a steel by-pass spring.

Dear Ms. Northrup:

In your letter, dated January 3, 2005, you requested a tariff classification ruling.

The merchandise, Dwg. number 310127, is a by-pass spring made from steel wire. The by-pass spring is a helical compression spring that will be utilized as a component of an automotive shock absorber or an automotive strut.

The applicable subheading for the steel by-pass spring will be 7320.20.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for springs and leaves for springs, of iron or steel: helical springs: suitable for motor-vehicle suspension. The general rate of duty will be 3.2% ad valorem.

Consideration was given to classifying the product within subheading 8708.99.7060, HTS, as you had suggested. However, springs of base metal are parts of general use and by virtue of note 1(g) to section XVI, classification in section XVI is precluded.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R.).

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 Kathy Campanelli at 646-733-3021.

Sincerely,

Robert B. Swierupski
Director,

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