CLA-2-84:RR:NC:1:102 C88892

Mr. Matthew J. Clark

Howrey & Simon

1299 Pennsylvania Avenue, NW

Washington, DC 20004-2402

RE: Classification of unfinished steel vanes from Japan.

Dear Mr. Clark:

In your letter dated May 22,1998 you requested a tariff classification ruling on behalf of your client Hitachi Metals America.

The items in question are unfinished steel vanes imported for use as parts in automotive power steering pumps. Descriptive information and samples were submitted.

You indicate that the subject vanes are manufactured and exported for sale to specific end users in the United States. The vanes are engineered to the specifications required of these end users and are dedicated for use as impellers for hydraulic fluid pumps. However, in their condition as imported, the vanes are not ready for direct use as parts of pumps and undergo finish-

grinding prior to final delivery.

In comparing a sample of an unfinished vane to a sample of a finished vane, we find that the finish-grinding appears to merely polish the surface of the vane and does not significantly change the shape or dimensions of the unfinished vane. The unfinished article has the essential character of the finished vane.

The applicable subheading for the unfinished steel vanes will be 8413.91.9050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of hydraulic fluid power pumps. The rate of duty will be 0.6 percent ad valorem.

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 212-466-5493.

Sincerely,

Robert Swierupski

Chief, Metals and Machinery Branch

National Commodity

Specialist Division