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NY 888392

August 11, 1993

CLA-2-84:S:N:N3:102 888392


TARIFF NO.: 7318.15.5000; 7318.15.6000; 8481.90.3000; 8481.90.5000; 8483.30.8090

Ms. Sharon K. Edwards
500 Simpson Avenue
P.O. Box 1167
Elkhart, IN 46515-1167

RE: The tariff classification of various parts of hand operated valves from Mexico

Dear Ms. Edwards:

In your letter dated July 13, 1993 you requested a tariff classification ruling.

You indicated in your correspondence that you plan to import all of the necessary components to produce several sizes of steel ball valves. It is your company's intention to assemble these valves together in the United States. The parts consist of the following: stainless steel bodies, stems, balls, pipe ends, stem seal followers and handles; teflon thrust plain bearings; stem seals, body seals and valve seats, made of either Buna, Neoprene, Viton, Teflon, etc.; plastic handle sleeves; stainless steel Belleville washers and lock washers; steel hex nuts and body nuts; steel body bolts; and steel stop screws.

The applicable subheading for the steel bodies, stems, balls, pipe ends, stem seal followers and handles will be 8481.90.3000, Harmonized Tariff Schedule of the United States (HTS), which provides for iron or steel parts of hand operated valves. The rate of duty will be 8 percent ad valorem. The stem seals, body seals and valve seats will be classifiable under HTS item 8481.90.5000 as parts of hand operated valves, made of materials other than copper, iron, steel, rubber, glass or ceramic. The rate of duty will be 4.4 percent ad valorem. The teflon thrust plain bearing is classified under the provision covering plain shaft bearings, item 8483.30.8090. The rate of duty is 5.7 percent ad valorem.

The applicable subheading for the steel Belleville washers and the lock washers will be 7318.21.0000, HTS, which provides for spring washers and other lock washers, of iron or steel. The duty rate is 5.8 percent ad valorem. The steel body bolts are classified under HTS item 7318.15.5000, which covers iron or steel studs. They are dutiable at 4.7 percent ad valorem. The HTS provision covering steel hex nuts and body nuts is 7318.16.0090, with a duty rate of 0.2 percent ad valorem. The classification of the stop screws varies based on the size of the screw. HTS item 7318.15.6000 covers socket head screws having shanks or threads with a diameter of less than 6 mm. It has a duty rate of 6.2 percent ad valorem. HTS number 7318.15.8040 covers socket head screws having shanks or threads with a diameter of 6 mm or more. It has a duty rate of 9.5 percent ad valorem.

Articles classifiable under subheading 7318.21.0000, 7318.15.5000, 7318.16.0090, 7318.15.6000, 7318.15.8040, 8481.90.3000, and 8481.90.5000 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.

You also queried in your letter regarding whether the country of origin marking requirements could be waived for all of these components based on the fact that they would not be sold separately in the U.S. but would be assembled into a complete valve before sale. It is our opinion that, at minimum, we would require that the assembled valves be marked " Assembled in the U.S. of Mexican components". Other than that, we would not waive the requirement that each individual part would have to bear the country of origin in a permanent, legible and conspicuous manner.

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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