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 cover from Japan

Dear Ms. Jenkins:

In your letter dated August 18, 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 cover, part number 132616. The cover is made of cast aluminum and is incorporated into an automobile’s brake booster assembly. You indicate that this part sits inside the brake booster and holds the primary piston and seals the bottom of the master cylinder to prevent brake fluid from leaking.

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 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 within the master cylinder which forces hydraulic fluid into the brake lines to actuate the vehicle’s brakes. Brake booster assemblies were previously ruled upon in New York Ruling N014493 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 master cylinder cover is an integral component of the mechanism used in positive displacement piston pumps to provide fluid power in hydraulic systems.

The applicable subheading for the master cylinder cover 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