CLA-2-84:RR:NC:1:102 F84385

Ms. Audrey Chinavare
Volkswagon of America
3800 Hamlin Road - 4E03
Auburn, Hills, Michigan 48326

RE: The tariff classification of a component of an anti-locking brake system from Germany

Dear : Ms. Chinavare

In your letter dated March 13, 2000 you requested a tariff classification ruling on behalf of Volkswagon of America.

The item in question is identified as part number 535 614 111 and described as an ABS unit for anti-locking brake systems. Anti-lock brake systems use an electronic control system to modify the operation of a vehicle brake hydraulic system to prevent wheel lockup during periods of hard braking. Descriptive literature and a sample of the ABS unit were submitted.

The ABS unit in question is essentially a fluid power pump comprised of an electrically operated hydraulic pump, an accumulator and a series of control valves. The hydraulic pump is used to provide pressurized brake fluid to the accumulator, which in turn generates charging pressure within the ant-locking brake system. The pump and accumulator, together with the control valves, allow the ABS unit to supply and modulate brake fluid pressure within the vehicle’s braking system while in anti-lock mode.

The applicable subheading for the ABS unit will be 8413.60.0040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other hydraulic fluid power pumps. The rate of duty is free.

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 212-637-7026.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division