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NY 894588

February 22, 1994



TARIFF NO.: 8708.99.7060

Mr. Roger M. Golden
Fenwick & West
1920 N Street, NW
Suite 650
Washington, DC 20036

RE: The tariff classification of cylinder bottoms from Spain

Dear Mr. Golden:

In your letter dated January 28, 1994, on behalf of Sachs Automotive of America (SAA), Troy, MI, you requested a tariff classification ruling. You have submitted three samples of the products.

The imported products are called cylinder bottoms (also referred to as base valves or valve bottoms). The three model numbers are SAA part no. 5DLHX003, SAA part no. 5DLFX004 (1724-295-100), and SAA part no. 1734-294-001. The products are made of sintered metal (powdered metal). They are used as components of shock absorber assemblies. The cylinder bottom is the part to which the other components of the shock absorber, such as washers and springs, are riveted (to form the base of the shock absorber assembly).

The SAA 5DLHX003 is circular in shape and has a diameter of approximately 1-1/2 inches.

The SAA 5DLFX004 (1724-295-100) is circular in shape and has a diameter of approximately 1-3/8 inches.

The SAA 1724-294-001 is circular in shape and has a diameter of approximately 1-1/4 inches.

The shock absorber itself is attached to the motor vehicle in such a way that, as the wheel moves up and down, the shock absorber shortens and lengthens, or telescopes and extends. Since the shock absorber imposes a restraint on this movement, excessive wheel and spring movements as well as spring oscillations are prevented. The imported products are part of the shock absorber assembly.
The applicable subheading for the cylinder bottoms (part numbers SAA 5DLHX003, SAA 5DLFX004 (1724-295-100), and SAA 1734- 294-001) will be 8708.99.7060, Harmonized Tariff Schedule of the United States (HTS), which provides for parts and accessories of the motor vehicles of headings 8701 to 8705: other: parts for suspension systems. The rate of duty will be 3.1 percent ad valorem.

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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