CLA-2-84:RR:NC:1:102 G89404

Mr. Kevin Egan
E. Besler & Company
PO Box 66361
Chicago, Illinois 60666-0361

RE: The tariff classification of a siphon pump from China and Taiwan.

Dear Mr. Egan:

In your letter dated March 26, 2001 you requested a tariff classification ruling on behalf of your client Raydyot/Koehler.

The article in question is described as a transfer siphon pump, item number RA990, packaged together with accessory fittings and plastic tubing. A sample was submitted.

Examination of the sample reveals that the siphon pump is a multi-use pump. The design of the pump and the accessories with which the pump is presented allow it to function as both an air pump, for inflating articles such as tires, and a liquid pump, for transferring volumes of liquids such as oil and gasoline. The pump is operated by hand.

Liquid pumps are provided for in heading 8413, Harmonized Tariff Schedule of the United States (HTSUS). Air pumps are provided for in heading 8414, HTSUS. The General Rules of Interpretation (GRI) to the HTSUS govern classification of goods in the tariff. In accordance with GRI 3(c), the subject pump shall be classified under the heading that occurs last in numerical order.

The applicable subheading for the siphon pump will be 8414.20.0000, HTSUS, which provides for hand-operated air pumps. The rate of duty will be 3.7 percent ad valorem.

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 212-637-7026.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division