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NY 888955

August 6, 1993



TARIFF NO.: 8424.10.0000

Mr. A J Phillips
Fire & Safety Training Ltd.
P.O. Box 999
Ruthin, Clwyd LL15 1AJ
United Kingdom

RE: The tariff classification of a fire extinguisher from England.

Dear Mr. Phillips:

In your letter dated July 27, 1993 you requested a tariff classification ruling. You submitted technical and descriptive literature with your request.

The "Firetrace" automatic fire extinguisher is a simple self- activating linear fire extinguisher designed for installation inside enclosed areas such as cabinets, machinery housings, engine compartments and the like. It comprises a length of special flexible polymer containing a fire extinguishing medium under pressure. When heated the tubing softens and the internal pressure causes it to rupture at the hottest point, thereby spraying the extinguishant onto the core of the fire. Connected to one end of the trace tube is a gauge showing the internal pressure. For larger areas a reservoir of extinguishant is connected to the tube; these reservoirs are of the standard fire extinguisher type. All the usual extinguishing media may be used: water, powder, halon, CO2, and NAFS3.

The applicable subheading for the "Firetrace" fire extinguisher will be 8424.10.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for fire extinguishers, whether or not charged. The rate of duty will be 3.7 percent ad valorem.

Your inquiry also asks about possible import restrictions with regard to the extinguishing media. You should know that some extinguishants, notably halon and similar extinguishing media, may be subject to the regulations of the Environmental Protection Agency, Global Change Division. You may contact them at 401 M Street SW, Washington, D.C. 20460, telephone number (202) 233- 9131. Insofar as your request to know about any other possible import requirements with respect to importing your merchandise, you may direct any questions to the local import specialist or entry office at the district office where you will be entering your merchandise.

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

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