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NY N016879




October 1, 2007

CLA-2-39:RR:E:NC:N2:221

CATEGORY: CLASSIFICATION

TARIFF NO.: 4016.93.5050

Ms. Cheryl Smith
Star USA Inc.
250 N. Davis Road
Ashland, OH 44805

RE: The tariff classification of a motor mount seal from Taiwan

Dear Ms. Smith:

In your letter dated September 10, 2007, on behalf of Parker Hannifin Corporation, Composite Sealing Systems, you requested a tariff classification ruling.

Part #204055, described as a ThredSeal, is a six sided flat carbon steel washer with a nitrile rubber sealing element bonded to the center of the washer. It is used on a motor mount for industrial and residential air conditioning units. A motor mount stud passes through the center of the washer and the rubber sealing element seals against the threads of the motor mount. You suggest classification in subheading 7318.22.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for, among other articles, washers of iron or steel. A washer is designed to protect the part or material that is being fastened. You state that the metal component limits the amount of compression on the sealing element and the rubber component keeps water from spiraling down the threaded motor mount studs and into the unit. According to the descriptive literature included with your request, ThredSeals function to block all leak paths in a threaded fastener and the key benefit is effective sealing for standard fastener sizes. In the opinion of this office, the primary function of part #204055 is its sealing ability, which is imparted by the nitrile rubber component.

The applicable subheading for the ThredSeal, part #204055, will be 4016.93.5050, HTSUS, which provides for other articles of vulcanized rubber other than hard rubber: other: gaskets, washers and other seals: otherother. The rate of duty will be 2.5 percent 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 Joan Mazzola at 646-733-3023.

Sincerely,

Robert B. Swierupski
Director,

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