CLA-2-84:RR:NC:1:104 I82420

Mr. Spiro Karras
Sandler & Travis Trade Advisory Services
38345 Ten Mile Road
Farmington Hills, Michigan 48335

RE: The tariff classification of catalytic converter/exhaust pipe assemblies from Canada

Dear Mr. Karras:

In your letter dated May 15, 2002 on behalf of Daimler Chrysler Corporation you requested a tariff classification ruling.

You describe catalytic converter/exhaust pipe assemblies, such as part # 04764485, which consist of a 75 mm steel inlet pipe at one end of the converter and a 477 mm outlet pipe at the other end. The catalytic converter itself measures about 252 mm long. The components are welded together. You state that the catalytic converter portion of the assembly, with its substrate of precious metals (platinum and rhodium) and heat shield, accounts for over 96 percent of the cost of the assembly. The assembly does not include the muffler, tail pipe, exhaust resonator or exhaust manifold.

You suggest that this assembly is a composite article and that the essential character is imparted by the catalytic converter. Noting GRI 3(b), you would classify under 8421.39.4000. This office agrees.

The applicable subheading for the catalytic converter/exhaust pipe assembly will be 8421.39.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for filtering or purifying machinery and apparatus for gases: other: catalytic converters. The rate of duty will be free.

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 Losche at 646-733-3011.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division