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NY B85015

June 26, 1997

CLA-2-84:RR:NC:1:102 B85015


TARIFF NO.: 8481.80.9050

Mr. Christian H. Siburn
Siburtek Marine Services Group
23 Manor Road
Ridgefield, CT 06877

RE: The tariff classification of an automatic life jacket inflator mechanism from Sweden.

Dear Mr. Siburn:

In your letter dated May 28, 1997 you requested a tariff classification ruling on behalf of C.M. HAMMAR AB.

The item in question is an automatic inflator mechanism for a life jacket inflation system. The inflator mechanism is designed to be attached to a life jacket and is used in conjunction with a compressed gas cylinder. A sample and descriptive literature were submitted.

The automatic inflator mechanism controls the flow of gas from the gas cylinder into the inflatable structure of the life jacket and can be activated either manually by operating a pull-cord or automatically by immersing the life jacket in water. The inflator mechanism consists of two parts which are made of a plastic material and identified as the "external cap" and the "internal body".

The external cap imparts the "automatic" feature of the inflator. It contains a hydrostatic valve, a water sensitive element that retains a stainless steel coil spring, and a pull-cord mechanism. A locking ring molded into the cap of the inflator mechanism secures and seals the cap onto the body and the life jacket. A "manual" external cap, containing only the pull-cord mechanism, is also available and is interchangeable with the automatic cap. The cap, which is designed to be disposable, must be replaced after each use and will be imported and sold separately.

The internal body is designed to hold the compressed gas cylinder and contains a spring loaded piercing device for puncturing the cylinder. Although the piercing device must be reset after each use, the internal body, unlike the external cap, is reusable. The internal body can be used with either the manual or the automatic cap.

When the automatic inflator is immersed in water, the hydrostatic valve contained in the automatic external cap opens and lets surrounding water flow onto the water sensitive element which retains the stainless steel coil spring. Upon contact with water the water sensitive element dissolves, causing a shaft passing between the cap and the body to rotate. The rotating shaft in turn causes the piercing mechanism in the body of the inflator mechanism to puncture the gas cylinder. The pressure of the compressed gas as it flows from the cylinder closes the hydrostatic valve and inflates the life jacket. The pull-cord mechanism simply allows the user to override the automatic feature and manually operate the piercing mechanism.

The applicable subheading for the automatic inflator mechanism, imported with or without the internal body, will be 8481.80.9050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for valves taps, cocks, valves and similar appliances as other appliances. The rate of duty will be 2.7 percent ad valorem.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Kenneth T. Brock at 212-466-5493.


Robert Swierupski
Chief, Metals and Machinery Branch

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