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NY R01405





March 11, 2005

CLA-2-40:RR:NC:N2:221 R01405

CATEGORY: CLASSIFICATION

TARIFF NO.: 4016.99.3500; 4016.99.6050

Ms. Shelley Vybiral
Lord Corporation
2000 West Grandview Blvd.
Erie, PA 16509

RE: The tariff classification of Hystec mounts and center bonded mounts from China.

Dear Ms. Vybiral:

In your letter dated February 8, 2005, you requested a tariff classification ruling.

Hystec mounts are used to reduce noise and vibration on engines for on-highway and off-highway vehicles. Center bonded mounts are used to isolate vibration, control shock and reduce noise due to structure borne vibrations. They are used in applications such as engines, cabs, fuel tanks, pumps, air conditioning units, compressors and industrial machinery. The center bonded mounts are constructed of either natural rubber or synthetic neoprene rubber and steel. The rubber component imparts the essential character to the center bonded mounts, since it is the component that absorbs the vibration and provides the shock protection and noise attenuation.

The applicable subheading for the center bonded mounts, when made of natural rubber, will be 4016.99.3500, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of vulcanized rubber other than hard rubber: other: of natural rubber: other. The rate of duty will be free.

The applicable subheading for the center bonded mounts, when made of neoprene synthetic rubber, will be 4016.99.6050, HTS, which provides for other articles of vulcanized rubber other than hard rubber: other: other. The rate of duty will be 2.5 percent ad valorem.

Your inquiry does not provide enough information for us to give a classification ruling on the Hystec mounts. Please provide a representative sample. Though you state that the product is made of natural rubber, the elastomeric component in the illustration does not appear to be natural rubber. Please provide the specific name of the type of rubber or elastomer in the damping disks. Specify if there are any other rubber components other than the damping disks. Provide a breakdown by cost and weight for the rubber components versus the steel components. Explain in full the function of the rubber components. Explain in full the function of the steel components.

Do the Hystec mounts have applications other than for on-road and off-road vehicles? What differences in designs or other features distinguish Hystec mounts used in on-road vehicles versus those used in off-road vehicles?

When this information is available, you may wish to consider resubmission of your request. If you decide to resubmit your request, please include all of the material that we have returned to you.

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 Joan Mazzola at 646-733-3023.

Sincerely

Robert B. Swierupski
Director,
National Commodity
Specialist Division


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