CLA-2-84:RR:NC:1:102 E81445

Mr. Marc D. Torrence
V. Alexander & Co., Inc.
15 Century Blvd., Suite 400
Nashville, Tenn. 37214-3650

RE: The tariff classification of a pneumatic cylinder from China

Dear Mr. Torrence:

In your letter dated April 19, 1999 you requested a tariff classification ruling on behalf of V. Alexander & Company.

The item in question is identified as a pneumatic cylinder assembly used to convert pneumatic power to useful mechanical force. Air is the working pneumatic fluid. The cylinder will be incorporated in the Dezurik knife gate valve as an actuation component and provide linear force to open and close the valves.

The cylinder assembly consists of a cylinder, end caps sealed to the cylinder by tie-rods, a piston, and piston rod. The piston rod is joined at one end to the piston and at the other end to the valve gate. When air is introduced into the cylinder from the end nearest the valve, the air pressure moves the piston away from the valve. The piston pulls on the piston rod and the valve opens. When air is introduced to the opposite end of the cylinder, the pressure pushes the piston in the opposite direction and closes the valve.

The applicable subheading for the pneumatic cylinder will be 8412.31.0040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for linear acting pneumatic cylinders, tie-rod type. The rate of duty is 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 Kenneth T. Brock at 212-637-7026.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division