HQ 088062
                                          DEC 28 1990
            CLA-2:CO:R:C:G   088062 JAS
Alan Litwin
            F.W. Myers & Co., Inc.
            55 Oriskany Drive
            Tonawanda, New York 14150
            RE:  Screens, Perforated Stainless Steel; Filtering,
                 Separating Elements; Machinery Parts
            Dear Mr. Litwin:
                 In your letter of September 12, 1990, on behalf of your
            client Erdle Perforating Co., Rochester, N.Y., you inquire as
            to the tariff classification of perforated stainless steel
            screens from Japan.  Our ruling follows.
            FACTS:
                 The articles in issue here are finished screens made from
            cold rolled stainless steel, 2mm. thick or less, which have
            been die stamped to produce precision perforated holes or
            slots.  The screens are used in separating, atomizing,
            filtering and straining applications in the food, paper and
            pharmaceutical industries, as well as in other industrial
            applications.
                 Most screens are imported cut to size and ready for use.
            For shipping and handling purposes, however, some are imported
            as flat rolled products in material lengths in coils and in
            varying widths and thicknesses.  After importation, the
            customer cuts them to size with no further processing required.
            Principal use of these screens with a particular machine or
            class of machines has not been established.
            ISSUE:
                 Whether these screens are classifiable as parts of
            machines for tariff purposes.
- 2 -
            LAW AND ANALYSIS:
                 Merchandise is classifiable under the Harmonized Tariff
            Schedule of the United States Annotated (HTSUSA) in accordance
            with the General Rules of Interpretation (GRIs).  GRI 1 states
            in part that for legal purposes, classification shall be
            determined according to the terms of the headings and any
            relative section or chapter notes and, provided the headings or
            notes do not require otherwise, according to GRIs 2 through 6.
                 Goods that qualify as parts in a tariff sense but are
            either not covered in a specific heading in chapters 84 or 85
            or are not found to be suitable for use solely or principally
            with a particular kind of machine, or with a number of machines
            of the same heading, are to be classified in heading 8485, if
            non-electrical, or in heading 8548 if electrical.  Section XVI,
            Note 2(c), HTSUSA.  Because of its design and function, a
            finished perforated screen is an integral, constituent and
            component part necessary to the proper functioning of any
            machine it may be used with.  However, there is no evidence of
            principal use with a particular kind of machine or with
            machines of one heading.
                 Perforated stainless steel screens in material lengths, in
            coils, do not assume the character of machinery parts of
            section XVI.  They are provided for in chapter 72 as flat-
            rolled products of stainless steel.  Chapter 72, Note 1(k),
            HTSUSA.  In the absence of specific dimensions as to width and
            thickness, we are unable to confirm a particular classification
            for this merchandise.
            HOLDING:
                 Perforated stainless steel screens are provided for in
            heading 8485, as machinery parts not containing electrical
            features.  Actual classification is in subheading 8485.90.0000,
            HTSUSA, other parts.  The rate of duty is 5.7 percent ad
            valorem.
                                        Sincerely,
                                       John Durant, Director
                                       Commercial Rulings Division