CLA-2-84:RR:NC:MM:106 E88517

Dr. John Niu
Nutech Company
2787 Cottonwood Court
Clearwater, FL 33761

RE: The tariff classification of stainless steel rings for instantaneous gas water heaters from China.

Dear Dr. Niu:

In your letter dated October 5, 1999, as a follow-up to our request for additional information based upon your previous letter of August 24, 1999, you requested a tariff classification ruling. You submitted representative samples and descriptive literature with your request.

These stainless steel rings, made of 304 stainless steel coil by a press machine, act as the heat transfer medium in instantaneous gas water heaters. Each ring measures approximately 2.5 inches in circumference by 1 inch in height, and weighs approximately 0.03 lbs. As hot combustion gases flow upward in the instantaneous gas water heater, the stainless steel rings are heated. Simultaneously, cold water flows downward through the heated stainless steel rings, heating up the rings. The heated water is then stored at the bottom of the water heater. You state that these stainless steel rings are for use solely or principally in instantaneous gas water heaters. You also indicate that the instantaneous gas water heaters are used only for industrial applications.

The applicable subheading for the stainless steel rings for instantaneous gas water heaters will be 8419.90.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts of instantaneous or storage water heaters. The rate of duty will be 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 Patrick J. Wholey at 212-637-7036.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division