CLA-2-84:RR:E:NC:N1:102

Mr. Timothy Lumpkin
Viable Energy Alternatives
2407 Lindsey Dr.
Copperas Cove, TX 76522

RE: The tariff classification of mechanical seals and parts of mechanical seals from Russia.

Dear Mr. Lumpkin:

In your letter dated May 11, 2007, you requested a tariff classification ruling on behalf of Viable Energy Alternatives.

The items in question are described as components of a mechanical seal and are identified as a gland, a clamp ring, a pivot ring, a spacer ring, a rotary, a drive band and a sleeve. You indicate that the components may be imported separately as parts for use in the assembly of complete mechanical seals or assembled abroad and presented upon importation as complete seals.

Mechanical seals are provided for eo nomine in heading 8484 of the Harmonized Tariff Schedule of the United States (HTSUS). However, the heading does not provide for parts of such seals. It appears that the mechanical seals in question are used in a range of industrial applications in which their principal use is to prevent the leakage of liquid media in fluid handling pumps. The components of the mechanical seals are provided for as parts of liquid pumps in heading 8413, HTSUS.

The applicable subheading for the mechanical seal, when presented as a complete unit, will be 8484.20.0000, HTSUS, which provides for mechanical seals. The rate of duty will be 3.9 percent ad valorem.

The applicable heading for the components of the mechanical seal when presented separately as parts will be 8413.91.9080, HTSUS, which provides for other parts of liquid pumps. The rate of duty is free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 646-733-3009.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division