Ms. Kristin Van Beem
Trek Bicycle Corporation
801 West Madison Street
Waterloo, WI 53594

RE: The tariff classification of “Avid® Hydraulic Disc Brake Bleed Kit” from Taiwan

Dear Ms. Van Beem:

In your letter dated May 3, 2010, you requested a tariff classification ruling.

The subject product, “Avid® Hydraulic Disc Brake Bleed Kit,” Model Number 411452, is imported from Taiwan. The kit includes several components that are used together to bleed air from the hydraulic brake systems and to replace the old brake fluid with the new fluid. It is the hydraulic fluid which enables the brakes to function. Based on the product information submitted and pictures, the components are packaged ready for retail sale inside a paperboard box. It includes 4 fluid ounces of Avid® Hydraulic Fluid, two plastic bleed syringes, plastic clamp tubes with metal fittings, metal compression fittings, a metal L-wrench, and metal and plastic hose barbs.

Merchandise imported into the United States is classified under the HTSUS. Tariff classification is governed by the principles set forth in the General Rules of Interpretation (GRI’s) and, in the absence of special language or context which requires otherwise, by the Additional U.S. Rules of Interpretation. The GRI’s and the Additional U.S. Rules of Interpretation are part of the HTSUS and are to be considered statutory provisions of law for all purposes. GRI 3(b) is applicable when goods are, prima facie, classifiable under two or more headings, and have been put up in sets for retail sale. GRI 3(b) states that the goods "shall be classified as if they consisted of the material or component which gives them their essential character." In this case, we agree with you that the Hydraulic Fluid imparts the essential character of the set.

The applicable subheading for the Avid® Hydraulic Disc Brake Bleed Kit will be 3819.00.0010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Hydraulic brake fluids and other prepared liquids for hydraulic transmission, not containing or containing less than 70 percent by weight of petroleum oils or oils obtained from bituminous minerals; Hydraulic brake fluids.” The rate of duty will be 6.5 percent ad valorem.

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

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 Paul Hodgkiss at (646) 733-3046.


Robert B. Swierupski
National Commodity Specialist Division