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NY 853717

July 18, 1990

CLA-2-84:S:N:N1:102 853717


TARIFF NO.: 8481.10.0000

Mr. Dale Munn
Racine Fluid Power, Inc.
7505 Durand Ave.
Racine, Wisconsin 53406

RE: The tariff classification of combination filter-regulator- lubricator (FRL) from France

Dear Mr. Munn:

In your letter dated June 18, 1990 you requested a tariff classification ruling.

The item in question is a combination air filter, pressure regulator, and pneumatic lubricator. Since unregulated compressed air often contains water vapor and harmful particles that could damage a system, a FRL is a common accessory installed in the pneumatic line. The filter removes the contaminants and water vapor; the regulator controls the downstream air pressure, and the lubricator injects a fine oil mist into the air supply by means of the venturi principle. The three components are pre- assembled and sold as an entirety. Based on the literature provided it appears that the function of the filter and regulator are always required in a pneumatic system, and that the lubrication function is required a significant amount of time.

In that we would view the FRL as a composite article, for classification purposes, and one in which there is no one essential function, we would revert to Rule 3 (c) of the General Rules of Interpretation of the Harmonized Tariff Schedules. In brief summary, Rule 3(c) states that such an article would be classified in that HTS provision which appears last among all of the eligible competing provisions.

The applicable subheading for the FRL will be 8481.10.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for pressure-reducing valves. The rate of duty will be 3.7 percent ad valorem.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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