CLA-2-84:OT:RR:NC:N1:102
Ms. Nicole M. Jenkins
Crowell & Moring LLP
1001 Pennsylvania Ave. NW
Washington, DC 20004
RE: The tariff classification of a master cylinder plate from Japan
Dear Ms. Jenkins:
In your letter dated August 10, 2010 you requested a tariff classification ruling on behalf of your client, Aisin Holdings of America, Inc. Descriptive literature, a schematic drawing and a photograph were submitted.
The article in question is described as a master cylinder plate, part number 132272. The plate is made of SPC-440 grade steel, and its primary function is to provide reinforcement in the master cylinder of an automobile’s brake booster.
The brake booster is comprised of several components, including a hydraulic booster, an accumulator and a master cylinder that is separated into two chambers by a primary and a secondary piston. When the brake pedal is depressed, an electric motor within the booster drives a piston pump to discharge hydraulic fluid into an accumulator. The increased hydraulic pressure within the accumulator is then used to drive the primary and secondary pistons in the master cylinder which forces hydraulic fluid into the brake lines to actuate the vehicle’s brakes. The plate acts as reinforcement between the piston sub-assembly and the master cylinder body.
Brake booster assemblies were previously ruled upon in New York Ruling N096530 as other reciprocating positive displacement pumps for hydraulic fluid in subheading 8413.50.0080, Harmonized Tariff Schedule of the United States (HTSUS).
Based on the information submitted, we find that the subject plate is an integral part of the mechanism used in positive displacement piston pumps to provide hydraulic fluid into brake lines to actuate the vehicle’s brakes.
The applicable subheading for the master cylinder plate will be 8413.91.9050, HTSUS, which provides for parts of hydraulic fluid power 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