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

Mr. Christopher Reynolds
Barthco International, Inc.
dba OHL International
5101 S. Broad St.
Philadelphia, PA 19112-1404

RE: The tariff classification of various automotive components

Dear Mr. Reynolds:

In your letter dated December 9, 2011 you requested a tariff classification ruling on behalf of your client, SKF USA, Inc.

The items under consideration are parts for use in automotive vehicles. Descriptive literature and representative samples were included with your submission. The samples will be returned to you as requested.

Item number 531562-55 is described as the SCOTSEAL Classic. This component is designed for use in the drive axle assembly of commercial grade automotive vehicles and functions to provide a seal, combat contaminants and retain lubricants. It consists of a metal stamping, a garter spring and a sealing element made of nitrile polymer, a synthetic rubber.

Item number 550605-22 is described as the SCOTSEAL XL. This component is designed for use in the drive axle assembly of commercial grade automotive vehicles and is said to provide a seal, confine pressure, combat contaminants and retain lubricants. It consists of a metal stamping, a garter spring, hydrogenated rubber and a sealing element made of synthetic rubber.

Item number 548071-60 is described as a bonded piston seal for use in an automatic transmission of an automotive vehicle. The component is designed to convert hydraulic pressure into linear motion by engaging specific gears when stroked under fluid pressure and also creates a seal when pressurized. The main function of this part is not to provide a seal. It is comprised of a metal stamping and a sealing component of hydrogenated nitrile polymer.

The applicable subheading for the SCOTSEAL Classic, item number 531562-55, and the SCOTSEAL XL, item number 550605-22 will be 4016.93.1050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of vulcanized rubber other than hard rubber…gaskets, washers and other seals: of a kind used in the automotive goods of chapter 87…other. The general rate of duty will be 2.5 percent ad valorem.

The applicable subheading for the bonded piston seal, item number 548071-60, will be 8412.90.9005, HTSUS, which provides for parts of linear acting hydraulic power engines and motors. The general 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/.

Additional information is needed to classify item number 547863-34 which is described as a tone ring assembly for use in the Vehicle Stability Enhancement System (VSES) of a General Motors automotive vehicle. You state that the teeth in the outer metal stamping of the tone ring allow a sensor to measure revolutions per minute (RPM). Please explain exactly how the HUB sensor and the tone ring work together. What electrical, magnetic, optical, etc, phenomenon/principle do they use to function? Does the merchandise concerned perform any other function?

When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.

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 classification of the SCOTSEAL Classic and the SCOTSEAL XL, contact National Import Specialist Joan Mazzola at (646) 733-3023. If you have any questions concerning the classification of the bonded piston seal, contact National Import Specialist Kenneth T. Brock at (646) 733-3009.

Sincerely,

Thomas J. Russo
Director
National Commodity Specialist Division