CLA-2-84:RR:NC:MM:106 L81433

Ms. Kimberly Novak
Menlo Worldwide Trade Services
6940 Engle Road
Middleburg, OH 44130

RE: The tariff classification of brake assemblies for riding lawnmowers from China

Dear Ms. Novak:

In your letter dated December 8, 2004, on behalf of your client Hydro-Gear, you requested a tariff classification ruling. You submitted a sample with your request as well as engineering drawings. Your sample will be returned.

The merchandise at issue is five models of brake assemblies. Your product numbers are as follows: 71207, 71204, 71205, 71206, and 71278. You state that these assemblies are parts of “zero-turn” lawnmowers, which you describe as riding lawnmowers having the ability to turn in a complete circle while remaining virtually in place. You mention several brand names of “zero-turn” riding lawnmowers on which these assemblies will be used: Ariens, Snapper, Cub Cadet and Bad Boy.

The applicable subheading for the wheel brake assemblies will be 8433.90.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts for mowers for lawns, parks or sports grounds. The rate of duty will be 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 Patrick Whole at 646-733- 3013.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division