CLA-2-84:S:N:N1:102 873269

9032.89.6085

Mr. Joseph L. Giumentaro
Ameri-Can Customhouse Brokers, Inc.
Peace Bridge Plaza
Buffalo, N.Y. 14213-2488

RE: The tariff classification of various hydraulic control valves from Italy, as well as electronic interlock units, electrical relays, and microprocessor based transmission controllers from Sweden

Dear Mr. Giumentaro:

In your letter dated April 3, 1992, on behalf of your client, Flo Draulic Controls, Ltd., Ontario, Canada, you requested a tariff classification ruling.

The items involved in this ruling consist of the following: hydraulic modular remote controls; hydraulic directional control valves; electronic forward/reverse interlock units; electronic relay boxes; and the RMH "Shiftronic" electronic transmission control system.

The modular hydraulic remote control, model HC-MC, is a manually operated directional control valve that resembles a joystick. The unit controls the flow of hydraulic fluid to to other components in the hydraulic network, and functions as the principal interface between the equipment being operated and the operator running it. The model HC-D20 directional control valve performs the same basic functions as the HC-MA, is also manually actuated, but has a different physical arrangement. The applicable subheading for the models HC-MA and HC-D20 hydraulic valves will be 8481.20.0010, Harmonized Tariff Schedule of the United States (HTS), which provides for directional control hydraulic power transmission valves. The rate of duty will be 3.7 percent ad valorem.

The electronic forward/reverse interlock unit is designed for vehicle use, where it prevents the driver from shifting between a forward and reverse gear if the rpm of the transmission is too high. If the gear-shift control is moved from one direction to the other, when the transmission speed is greater than the programmed rpm, the electric circuit between the shifter and the selector valve on the transmission is interrupted, thus preventing any directional change. The interlock unit will be classifiable under 8536.30.0000, HTS, which provides for other electrical apparatus for protecting electrical circuits. The rate of duty will be 5.3 percent ad valorem.

The RMH relay box is a 12 or 24 volt DC electrical connection box containing six relays, each relay equipped with one green and one red LED. The unit is designed to simplify the installation of electrical equipment in vehicles. The relay box is classifiable under the provision covering electrical relays, other, other, contactors, HTS item 8536.41.0045, with a duty rate of 5.3 percent ad valorem.

The RMH Shiftronic is a universal electronic control system which provides full overview and control of automatic gear selection on any type of cycling transmission. The system consists of three main components: the electronic control unit (ECU), which processes all input data and generates the control signals; a cab display unit (CDU), with indicates the selected gear and provides self diagnostic display; and a speed sensor kit, which mounts near the transmission output shaft in order to read vehicle speed, and transmits this data to the ECU. Additional components may be added to the system to enhance its function. The ECU monitors several factors, such as vehicle speed, throttle position, engine oil pressure, coolant temperature, and torque converted load. It then compares these monitored signals to the originally programmed data and releases specific output signals to solenoid valves in the hydraulic transmission system.

The applicable subheading for the Shiftronic system will be 9032.89.6085, Harmonized Tariff Schedule of the United States (HTS), which provides for automatic regulating or controlling instruments and apparatus, other, other, other. 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