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NY R01634




April 15, 2005

CLA-2-87:RR:NC:1:101 R01634

CATEGORY: CLASSIFICATION

TARIFF NO.: 8708.70.6060

Mr. Dennis Forhart
PricewaterhouseCoopers LLP
1420 Fifth Avenue (Suite 1900)
Seattle, WA 98101

RE: The tariff classification of wheel hub and spoke wheel assemblies from the United States

Dear Mr. Forhart:

In your letter dated March 16, 2005 you requested a tariff classification ruling on behalf of your client Freightliner LLC.

The articles in question are described as wheel hub and spoke wheel assemblies used on road tractors for semi-trailers. Part number GUNHR841LF is a wheel hub assembly comprised of a wheel hub unit, wheel studs and two tapered roller bearings. Part number GUN TY233K is a six-spoke wheel assembly comprised of a wheel unit, wheel studs and two tapered roller bearings. Part number GUNHR935K8 is an assembly comprised of a wheel hub unit, two tapered roller bearings, wheel studs and an ABS ring. Part number GUN8355RH1 is an assembly comprised of a hub unit, brake rotor unit, two tapered roller bearings, wheel studs, lock nuts and bolts. Part number GUN3368 1 is an assembly comprised of a spoke wheel unit, brake drum unit, two tapered roller bearings, studs, bolts lock nuts and washers.

You state that you believe that the wheel hub and rotor assembly, part number GUN8355RH1 should be classified under HTS 8708.39.5030 as a brake rotor (disc). We disagree with your proposed classification because this item is developed beyond the essential character of a disc.

The applicable subheading for part numbers GUNHR841LF, GUN TY233K GUNHR935K8, GUN8355RH1, and GUN3368 1 will be 8708.70.6060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Road wheels and parts and accessories thereof: For other vehicles: Parts and accessoriesOther.

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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