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July 21, 1999

CLA-2-87:RR:NC:MM:101 E83892

CATEGORY: CLASSIFICATION

TARIFF NO.: 8708.39.5050, 8708.93.7500

Ms. Martha L. Brown
Volkswagen of America
3800 Hamlin Road - 4E03
Auburn Hills, Michigan 48326

RE: The tariff classification of a Pad for a Brake Pedal and a Pad for a Clutch Pedal from Germany

Dear Ms. Brown:

In your letter dated June 18, 1999 you requested a tariff classification ruling.

You submitted a drawing for each of the parts. Both pads are identified as Part Number: 447 721 173 on Drawing Number 173-18 #7.

The Pad for a Brake Pedal is made of plastic and is used to cover the brake pedal.

The Pad for a Clutch Pedal is made of plastic and is used to cover the clutch pedal.

The applicable subheading for the Pad for a Brake Pedal will be 8708.39.5050, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Brakes and servo-brakes and parts thereof: Other: For other vehicles┬Other. The rate of duty will be 2.5% ad valorem.

The applicable subheading for the Pad for a Clutch Pedal will be 8708.93.7500, 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 and accessories: Clutches and parts thereof: For other vehicles┬Other. The rate of duty will be 2.5% 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 Robert DeSoucey at 212-637-7035.

Sincerely,

Robert B. Swierupski
Director,

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