CLA-2-84:S:N:N1:103 863007
Ms. Therese E. Ignich
John V. Carr & Son Inc.
P.O. Box 33479
Detroit, MI 48232-5479
RE: The tariff classification of shock absorbers and chock
separators from France
Dear Ms. Ignich:
In your letter dated April 23, 1991 on behalf of Rotator
Products Ltd. you requested a tariff classification ruling.
Jarret shock absorbers absorb energy in order to reduce
shock forces, thus protecting equipment against excessive impact
loads. They achieve this result by means of the hydrostatic
compression of a specially formulated silicone elastomer. Each
shock absorber consists of a steel plunger with integral charging
valve, a plunger guide, a steel piston rod slightly smaller in
diameter than the plunger, and a seal. On impact the plunger,
which has been filled with the elastomer to a pre-determined
pressure, is driven over the smaller stationary piston. This
compresses the elastomer, forces it to flow through the orifice
between the plunger and piston, and causes the piston rod seal to
tighten. When the load has been brought to rest, the elastomer
pushes the plunger to its original position as it returns to its
pre-compressed volume. While the brochure submitted with your
inquiry indicates this product can be used in a wide variety of
applications, a letter from your client dated May 17, 1991 states
that ninety percent of such elastomeric shock absorbers are used
on overhead cranes to absorb impact shock caused when the crane
impacts the end of the crane runway.
Jarret chock separators (also known as stress limiters) are,
according to your client's letter, used exclusively in the
counterbalance of the work-roll assembly in a steel or non-
ferrous rolling mill. The weight of the top work roll and chock
assembly is supported on four Jarret separators. When the top
back-up roll is forced down on the top work roll under screw down
pressure to the desired roll gap, the Jarret units are compressed
and remain in that position during the rolling operation. When
the screw down pressure is removed, the separators force the top
work roll and chock assembly upwards to their fully extended
position. The units consist essentially of a heavy walled
plunger and a stationary piston. The central cavity of the
plunger is filled through a ball valve with the elastomeric
silicone fluid. The compressibility of the elastomer enables the
separators to act as springs.
The applicable subheading for the Jarret shock absorbers
will be 8431.49.1010, Harmonized Tariff Schedule of the United
States (HTS), which provides for other parts suitable for use
solely or principally with the machinery of subheading 8426.11
(overhead traveling cranes on fixed support). The rate of duty
will be 2 percent ad valorem.
The applicable subheading for the Jarret chock separators
will be 8455.90.0000, HTS, which provides for other parts of
metal-rolling mills. The rate of duty will be 4.9 percent ad
valorem.
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