CLA-2-84:RR:NC:1:103 I84422

Ms. Karin Bogue
Komatsu America International Company
Parts Division
108 N. Industrial Drive
Ripley, TN 38063

RE: The tariff classification of grease fittings from Japan

Dear Ms. Bogue:

In your letter dated July 11, 2002 you requested a tariff classification ruling.

With your inquiry you submitted a sample of a steel grease fitting, part number 42Y-00-H0040, as well as a diagram of the steering system in which it is used. This particular fitting resides at the end of a steering cylinder which is used in a model WA65 Komatsu Wheel Loader. The threaded end of the grease nipple is inserted into the steering cylinder and the other end is covered by a plastic security cap. During maintenance operations the security cap is removed, lubricant is inserted through the nipple, and the security cap is then replaced.

The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official interpretation of the Harmonized System at the international level. While not legally binding, the ENs provide a commentary on the scope of each heading of the Harmonized Tariff Schedule of the United States (HTS) and are generally indicative of the proper interpretation of these headings. In classifying goods, Customs believes the ENs should always be consulted (see T.D. 89-80). As you pointed out in your letter, the ENs for heading 84.85 state that this heading encompasses articles which are recognized as parts of machines, but not of any particular machine, such as greasing nipples.

Accordingly, the applicable subheading for the grease fittings will be 8485.90.0080, HTS, which provides for machinery parts, not containing electrical connectors, insulators, coils, contacts or other electrical features, and not specified or included elsewhere (in chapter 84): other: other. The rate of duty will be 3.9 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 Alan Horowitz at 646-733-3010.


Robert B. Swierupski
National Commodity
Specialist Division