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NY 848205

JANUARY 12, 1990

CLA-2-98:S:N:N1:105 848205


TARIFF NO.: 9802.00.80

Mr. Armando Trevino
A and A Customs Brokerage Services, Inc.
415 So. International Blvd.
P.O. Box AA
Hidalgo, Texas 78557

RE: The tariff classification of electrostatic air filters assembled from U.S. components in Mexico.

Dear Mr. Trevino:

In your letter dated November 29, 1989, on behalf of Border Quality Products Corporation, you asked about the tariff status of electrostatic air filter units assembled in Mexico from components of United States origin.

Following is a listing of the components that will comprise one complete unit to be assembled in Mexico: (1) molded housing (top, bottom, and two sides), (2) power supply p.c. board, (3) electrical contact board, (4) electrostatic collector cell assembly, (5) two grill and bracket assemblies, (6) two air filters (7) fan and motor assembly (fan blade, motor, capacitor, and mounting bracket), (8) label, (9) name plate, (10) button system switch,(11) wire, terminals and plugs, (12) indicator light, (13) interlock switch, and (14) power cord - 110 volt - 15 amp. The Mexican assembly operations are described as follows:


(1) Wire Harness - four wires are cut to length, ends are simultaneously stripped and terminals are added.

(2) Capacitor Assembly - Three wires are cut to length, ends are simultaneously stripped and terminals are added before connecting to capacitor.

(3) Plug Assembly - Consists of the wire harness with nine wires and two plugs - wires are cut to length and simultaneously stripped, and /or plugs forcefitted together.

(4) Supply Cord - Consists of three wires which are cut to length and simultaneously stripped and terminals forcefitted together.

(5) Fan and Motor Assembly - Manually attached by screwing together motor to mounting bracket; next attach fan blade to motor by screwing together; adding the capacitor assembly to the motor with two bolts and connecting the control panel, indicator light and interlocking switch to the mounting bracket by screwing together.


(1) Power supply and electric contact board is screwed onto base and the harness is plugged in.

(2) Side plates are combined with base by sliding on a tongue and groove configuration then grill and bracket assembly are screwed ont both ends to tie together.

(3) The air filter assembly is added by sliding into allocated space and name plate is mounted by gluing to outside grill assembly.

(4) Fan and motor assembly are added by sliding in and forcefitting onto its own grooved position.

(5) Wire harnesses are then connected by plugging in at indicated points.

(6) The collector cell is slid into place and the cabinet lid is screwed on.

(7) Finished unit undergoes checking and testing before placement in a cardboard box ready for shipping.

The applicable subheading for electrostatic air filters is under the provision for other filtering or purifying machinery and apparatus for gases, item 8421.39.0050, HTS, dutiable at 3.9 percent ad valorem. The subject assembly qualifies for treatment in item 9802.00.80, HTS, under the provision for articles assembled abroad in whole or in part of fabricated components, the product of the U.S. which were exported in condition ready for assembly without further fabrication and have not been advanced in value or condition abroad except by being assembled by operations incidental to the assembly process. Duty will be assessed upon the full appraised value of the imported article, less the cost or value of such products of the U.S.

Articles classifiable under subheading 8421.39.0050, HTS, which are products of Mexico, 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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