CLA-2-94:S:N:N8:233 888025

Mr. John W. Lee
EBI, Inc.
12411 McCann Drive
Santa Fe Springs, CA 90670

RE: The tariff classification of dental chairs from South Korea.

Dear Mr. Lee:

In your letter dated June 24, 1993, you requested a tariff classification ruling.

You intend to import dental chairs under the trade name of Medline. They include models YS-1000, YS-300 and YS-500. All three chairs have rotating, reclining and elevating features. They all feature a fully automatic hydraulic motorized system for up and down movement and a backrest control by foot and hand switch. The dental chairs will include American components such as air compressors and vacuum pumps that you purchase from suppliers in the United States. These will be shipped to your manufacturers in South Korea to be incorporated in the dental chairs.

The applicable subheading for the dental chairs will be 9402.10.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for dentists', barbers' or similar chairs and parts thereof. The duty rate will be 3.9 percent ad valorem. The applicable heading for the American components incorporated into the dental chairs will be 9802.00.80, HTS, which provides for articles assembled abroad in whole or in part of fabricated components, the product of the United States, which (a) were exported in condition ready for assembly without further fabrication, (b) have not lost their physical identity in such articles by change in form, shape or otherwise, and (c) have not been advanced in value or improved in condition abroad except by being assembled and except by operations incidental to the assembly process such as cleaning, lubricating and painting. The duty rate 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