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NY 853745

July 5, 1990

CLA-2-84:S:N:N1:102 853745


TARIFF NO.: 8413.60.0020; 8708.94.5000; 8708.99.5090

Ms. Elizabeth K. Zugschwert
Herman Ludwig Inc.
28969 Highlands Road
Romulus, Michigan 48174

RE: The tariff classification of hydraulic vane pumps, fluid reservoirs and steering gears from Brazil

Dear Ms. Zugschwert:

In your letter dated June 12, 1990, on behalf of your client ZF of North America, you requested a tariff classification ruling.

Your letter describes three main components of a hydraulic steering system used on vehicle class 6, 7, & 8 heavy duty trucks. The components, which are imported separately, are hydraulic pumps, hydraulic fluid reservoirs, and hydraulically- operated steering gears. The ZF models 7673, 7674, and 7677 are rotary positive displacement vane pumps which couple directly to the vehicle engine and provide the necessary hydraulic power for the steering mechanism. The models 7632 and 7636 oil tanks are made of heat resistant plastic and contain both a dirt particle filter and internal check valve. In addition, model 7632 includes an electric oil level switch. Their principal function is to act as a hydraulic fluid reservoir for the above pumps. ZF Servocom models 8095, 8097 & 8098 steering gears are compact "ball and nut" power steering units. By applying rotational torque from the steering wheel, a worm gear is turned and, under hydraulic power assistance, a piston section is moved, causing the road wheels to also turn.

The applicable subheading for the hydraulic vane pumps will be 8413.60.0020, Harmonized Tariff Schedule of the United States (HTS), which provides for other rotary, positive displacement, vane type hydraulic fluid power pumps . The duty rate will be 3 percent ad valorem.

The applicable subheading for the hydraulic reservoirs will be 8708.99.5090, HTS, which provides for other parts of motor vehicles of headings 8701 to 8705, other, other. The duty rate will be 3.1 percent ad valorem.

The three Servocom hydraulic steering gear models will be classifiable under the provision for steering wheels, steering columns and steering boxes for vehicles other than agricultural tractors, HTS subheading 8708.94.5000. The duty rate will be 3.1 percent ad valorem.

Articles classifiable under subheadings 8413.60.0020 and 8708.94.5000, HTS, which are products of Brazil are entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations.

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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