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NY 879831

November 12, 1992

CLA-2-73:S:N:N1:115 879831


TARIFF NO.: 7326.90.9090

Mr. Brice Harmand
Newen Inc.
3732 West Century Blvd. Unit 1
Inglewood, CA 90303

RE: The tariff classification of the spring master from France.

Dear Mr. Harmand:

In your letter dated October 12, 1992, you requested a tariff classification ruling.

The subject item is an apparatus known as the spring master. It is designed for use in assembling and disassembling cylinder- heads. The spring master consists of the following parts:

1) Wood table with a synthetic rubber membrane 2) Small bulb-type hand pump
3) Two steel long arm clamps
4) Steel central arm with gripper

In disassembling a cylinder head, the following steps must be accomplished:

1) Place the cylinder head on the work table and adjust the table up to a 45 degree angle by turning the knob located on the side of the table.

2) The two clamps can then be applied to the cylinder head.

3) The pump is then used to inflate the membrane. The membrane braces the valves on the entire surface of their heads, thus eliminating the risk of warping the valves.

4) The central arm is adjusted along with the correctly selected size gripper.

5) The central arm inertia hammer is then used to strike against the cylinder head spring, thereby loosening the key-bolts. The membrane acts as a shock absorber and pushes the valve against its seat. At this point, the work on the valves or the replacement of any interior parts, may be commenced.

Your merchandise is considered composite goods, consisting of different materials or made up of different components. This item shall be classified as if it consisted of the material or component which gives it its essential character. In this instance, the various steel parts impart the essential character.

The applicable subheading for the spring master will be 7326.90.9090, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel, other. The duty rate will be 5.7% ad valorem.

Consideration was given to classifying this product under the "Mechanical Appliances" category as you have suggested. However, the spring master cannot be defined as a mechanical appliance within the Customs' definition.

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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