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NY 882986

February 26, 1993



TARIFF NO.: 8511.80.6000

Mr. Philip Freeman
Cain Customs Brokers Inc.
P.O Box 10
Progreso, Texas 78579

RE: The tariff classification of a rotor from Mexico

Dear Mr. Freeman:

In your letter dated February 12, 1993, on behalf of Wells Manufacturing Company, McAllen, Texas, you requested a tariff classification ruling.

You have submitted a sample of the imported product which is a rotor, part no. 863700129, used inside the distributors of automobiles. The rotor body will be made of U.S. origin granulated thermo plastic which will be injection molded in Mexico. All the other parts (the screw, spring and vane) are of U.S. origin. The rotor will be assembled in Mexico.

The rotor is used to direct the electricity from the ignition coil to the spark plugs in certain automobile engines. The rotor is mounted on the distributor shaft. The spring on the rotor makes contact with the terminal in the center of the distributor cap, which comes from the ignition coil. As the shaft rotates, the rotor closes the circuit with the terminals in the cap that go to the spark plugs.

The applicable subheading for the rotor, part no. 863700129, will be 8511.80.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for other electrical ignition or starting equipment of a kind used for spark-ignition or compression-ignition internal combustion engines, other. The rate of duty will be 3.1 percent ad valorem.

Articles classifiable under subheading 8511.80.6000, HTS, which are products of Mexico may be entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations.

If the imported article is not eligible for GSP, then note that subheading 9802.00.80, HTS, provides a partial duty exemption for articles assembled abroad in whole or in part of fabricated components, the product of the United States, which (a) were exported in condition ready for assembly without further fabrication, (b) have not lost their physical identity in such articles by change in form, shape, or otherwise, and (c) have not been advanced in value or improved in condition abroad except by being assembled and except by operations incidental to the assembly process such as cleaning, lubricating, and painting.

All three requirements of subheading 9802.00.80, HTS, must be satisfied before a component may receive a duty allowance. An article entered under subheading 9802.00.80, HTS, is subject to duty upon the full value of the imported assembled article less the cost or value of such U.S. components, upon compliance with the documentary requirements of section 10.24 of the Customs Regulations (19 CFR 10.24). If you have any questions regarding subheading 9802.00.80, HTS, please address your request to U.S. Customs Service, Office of Regulations and Rulings, 1301 Constitution Ave., N.W., Washington, D.C. 20229-0001.

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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