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NY 869595

December 18, 1991



TARIFF NO.: 8708.39.5050

Mr. David J. Stansell
Davra Development Inc.
P.O. Box 105
Pittstown, NJ 08867

RE: The tariff classification of an unfinished brake shoe from the People's Republic of China

Dear Mr. Stansell:

In your undated letter to the U.S. Customs Service, you requested a tariff classification ruling. This request is a follow-up to your letter dated November 4, 1991. You have submitted a copy of a blue print and a sample of the imported product.

A complete brake shoe is an arc-shaped metal piece lined with heat resistant fiber, which is forced against the revolving brake drums to produce the braking action.

The imported product is an unfinished steel brake shoe designed for sole use on cars and trucks. The sample measures approximately 3 inches long by 1/4 inch thick, and has 7 holes of various sizes punched into the metal. After importation the surface of the steel is specially prepared: adhesive is applied to the steel, friction is applied with heat and pressure, the surface of friction is ground, clips and wear sensors are mechanically fastened to the steel plate, and the piece is painted and packaged.

The applicable subheading for the unfinished steel brake shoe will be 8708.39.5050, Harmonized Tariff Schedule of the United States (HTS), which provides for parts and accessories of motor vehicles; other brakes and servo brakes and parts thereof. The rate of duty will be 3.1 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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