CLA-2-84:S:N:N1:106 802897

Mr. Koji Tsujita
Honda Power Equipment MFG. Inc.
P.O. Box 37 Honda Drive NC Hwy119
Swepsonville, NC 27359

RE: The tariff classification of an engine assembly kit from Japan.

Dear Mr. Tsujita:

In your letter dated September 26, 1994 you requested a tariff classification ruling.

The engine assembly kit is to be assembled with other, domestically sourced parts to form the GXV160 engine. This engine is a 5.5 horsepower spark ignition internal combustion gasoline engine which will be installed in Honda Power Equipment lawn mowers. In its imported condition the engine kit is unfinished and unassembled. Each kit includes, packaged together, an engine short block assembly, a carburetor assembly and various other components and represents approximately seventy percent of the value of the complete engine. Taken together, these components, in their imported condition, have the essential character of a complete, assembled engine. These components undergo a relatively simple assembly process in which a three-man team assembles the kit components with other parts in approximately ten minutes.

The applicable subheading for the engine assembly kit will be 8407.90.1010, Harmonized Tariff Schedule of the United States (HTS), which provides for spark ignition internal combustion engines to be installed in agricultural or horticultural machinery of equipment. The rate of duty will be free.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director
New York Seaport