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NY M87548




October 25, 2006

CLA-2-73:RR:NC:N1:118 M87548

CATEGORY: CLASSIFICATION

TARIFF NO.: 7318.15.4000; 7318.21.0090; 7318.23.0000; 7318.29.00; 8473.30.9000

Mr. Darcy Firkus
General Manager
SpaceCo Business Solutions, Inc.
13100 East Albrook Drive, Suite 100
Denver, CO 80239

RE: The tariff classification of parts from China used to make a flat screen monitor arm.

Dear Mr. Firkus:

In your letter dated October 13, 2006, you requested a tariff classification ruling. You have described the items as steel parts used to make your “SpaceArm™,” which is a flat screen monitor arm. The parts are further identified as follows: SAM 221 – Knurl pin (6.33x51.7) with a black oxide finish. It is not threaded and has a knurled head. It is used to secure the components of the arm set together. SAM 222 – Height adjust bolt with a black oxide finish. It is a threaded steel mechanism with a socket head and modified cone point. Its function is to provide an easy way for the gas spring to change its position according to the weight of the monitor. Sam 225 – Flat head, partly hollow tubular rivet (5/16”x3/4”; ½” head diameter). It is intended to connect the gas spring with the arm base and provide a rotation feature. SAM 234 – Pan head torx screw (M5-0.8x15mm) is used to fasten the monitor mount with the arm part. SAM 236 – External tooth washer is used with the pan head screw.

The applicable subheading for the knurl pin (SAM 221) will be 7318.29.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: non-threaded articles: other. The duty rate will be 2.8% ad valorem.

The applicable subheading for the height adjust bolt (SAM 222) will be 8473.30.9000, HTSUS, which provides for parts and accessories (other than covers, carrying cases and the like) suitable for use solely or principally with machines of headings 8469 to 8472: parts and accessories of the machines of heading 8471: other: other. The duty rate will be free.

The applicable subheading for the partly hollow flat head tubular rivet (SAM 225) will be 7318.23.0000, HTSUS, which provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: non-threaded articles: rivets. The duty rate will be free.

The applicable subheading for the pan head torx screw (SAM 234) will be 7318.15.4000, HTSUS, which provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: threaded articles: other screws and bolts, whether or not with their nuts or washers: machine screws 9.5 mm or more in length and 3.2 mm or more in diameter (not including cap screws). The duty rate will be free.

The applicable subheading for the external tooth washer (SAM 236) will be 7318.21.0090, HTSUS, which provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: non-threaded articles: spring washers and other lock washers: other. The duty rate will be 5.8% ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Kathy Campanelli at 646-733-3021.

Sincerely,

Robert B. Swierupski
Director,

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