CLA-2-40:OT:RR:NC:N4:421
Mr. Christopher Reynolds
OHL Trade Services
5101 S. Broad Street
Philadelphia, PA 19112-1404
RE: The tariff classification of seals from Mexico
Dear Mr. Reynolds:
In your letter dated December 8, 2011, on behalf of SKF USA Inc., you requested a tariff classification ruling.
Four sample seals were included with your request. Item 537500-39 is described as a power steering pinion seal designed for use in the power steering system of an automotive vehicle. The component functions to provide a seal, protect against influx of contaminants and retain lubricants. It consists of a metal stamping, a garter spring, and a sealing element made of NBR (nitrile butadiene), a synthetic rubber.
Item 548443-60 is described as a rack seal designed for use in the power steering system of an automotive vehicle. It consists of a metal stamping, a garter spring, a nylon plastic insert, and a sealing element made of nitrile polymer, a synthetic rubber.
Item 548493-34 is described as a pinion seal designed for use in the pinion gear of a rear differential module of an automotive vehicle. It is said to provide a seal, combat contaminants and retain lubricants. It consists of a metal stamping, a garter spring, Krytox PFPE grease and a sealing element made of FKM polymer, a fluoroelastomeric considered to be of plastics for tariff purposes.
Item 548342-25 is described as a camshaft seal designed for use in the camshaft module of an automotive vehicle engine. It is said to provide a seal, retain lubricants, combat contaminants, reduce friction and separate fluids. It consists of a Zytel nylon plastic insert, a garter spring, and a sealing element made of FKM fluoroelastomeric plastics.
The applicable subheading for the seals with the rubber sealing elements, item 537500-39, power steering pinion seal, and item 548443-60, rack seal, will be 4016.93.1050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of vulcanized rubber other than hard rubber…gaskets, washers and other seals: of a kind used in the automotive goods of chapter 87…other. The general rate of duty will be 2.5 percent ad valorem.
The applicable subheading for item 548493-34, pinion seal for differential module, will be 3926.90.4590, HTSUS, which provides for other articles of plastics…gaskets, washers and other seals…other. The general rate of duty will be 3.5 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 http://www.usitc.gov/tata/hts/.
Your inquiry does not provide enough information for us to give a classification ruling on item 548342-25, camshaft seal for use in the camshaft module of an automotive vehicle engine. Your request for a classification ruling should include enough details about the component so that we can determine if the seal is solely or principally used as a part of the automotive engine. Exactly what is this camshaft seal attached to? Is it part of the camshaft itself or part of the connection between the camshaft and the engine? What role does in play in the operation of the engine? What role does it play in the operation of the vehicle? Provide a detailed diagram showing its location in the engine or vehicle. Specify whether the seal can be used in applications other than the engine of a motor vehicle. When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include a copy of this letter, a copy of your original request, and the sample of the camshaft seal.
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 Joan Mazzola at (646) 733-3023.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division