CLA-2-84:OT:RR:NC:N1:102
Ms. Nicole M. Jenkins
Crowell & Moring LLP
1001 Pennsylvania Ave. NW
Washington, DC 20004
RE: The tariff classification of a brake booster push rod sub-assembly and a valve stopper key from Japan
Dear Ms. Jenkins:
In your letter dated August 12, 2010 you requested a tariff classification ruling on behalf of your client, Aisin Holdings of America, Inc. Descriptive literature, schematic drawings and photographs were submitted.
The articles in question are described as a booster push rod sub-assembly, part number 131017, and a valve stopper key, part number 131141. You state that these parts are incorporated into an automobile’s brake booster assembly.
The brake booster is comprised of several components including a hydraulic booster, an accumulator and a master cylinder. The booster incorporates an electric motor that is used to drive a piston pump to discharge hydraulic fluid into an accumulator. The increased hydraulic pressure created within the accumulator is then used to drive a piston within the master cylinder forcing hydraulic fluid into brake lines to actuate the vehicle’s brakes.
Brake booster assemblies were previously ruled upon in New York Ruling N096530 as other reciprocating positive displacement pumps for hydraulic fluid in subheading 8413.50.0080, Harmonized Tariff Schedule of the United States (HTSUS).
The push rod sub-assembly is made of steel and sits inside the booster body. When the brake pedal is depressed, the booster assembly increases the braking force which pushes the rod sub-assembly into the master cylinder piston. Hydraulic fluid within the master cylinder is then passed through the brake lines causing the brake pads to engage and stop the vehicle. In addition, you indicate that the push rod determines the stroke length of the piston and can be adjusted accordingly to ensure the correct gap exists between the master cylinder piston and the booster push rod to ensure the components function properly.
The valve stopper key is also made of steel and secures the air valve to the booster piston. This ensures that the air valve remains centered and moves with the piston. Additionally, the key positions the air valve and prevents it from moving any further through the booster when the brakes are not being applied.
Based on the information submitted, we find that the subject brake booster push rod sub-assembly and valve stopper key are incorporated into a type of pump machinery (i.e. brake booster) and are integral parts of the mechanism used to create hydraulic pressure needed to push brake fluid through the brake lines in order to stop the vehicle.
The applicable subheading for the booster push rod sub-assembly and the valve stopper key will be 8413.91.9050, HTSUS, which provides for parts of hydraulic fluid power pumps. The rate of duty is free.
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 http://www.usitc.gov/tata/hts/.
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 (646) 733-3009.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division