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NY E89997

December 10, 1999

CLA-2-73:RR:NC:1:118 E89997


TARIFF NO.: 7318.24.0000

Ms. Janie Herrers
Sanden International (U.S.A.), Inc.
601 South Sanden Blvd.
Wylie, TX 75098-4999

RE: The tariff classification of a fixed key from Japan.

Dear Ms. Herrers:

In your letter dated November 16, 1999, you requested a tariff classification ruling.

You stated that the product is called a fixed key, part number 7801-0320. This small key is square-shaped, 1 3/8” in length and made of steel. It will fit into the groove of a fixed gear and hold the fixed gear in place inside a cylinder block for motor vehicles. Your submitted sample will be returned to you as requested.

The applicable subheading for the fixed key will be 7318.24.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers and similar articles, of iron or steel: non-threaded articles: cotters and cotter pins. The duty rate will be 3.8% ad valorem. In the year 2000, the duty rate will also be 3.8% ad valorem.

Consideration was given to classifying this product under subheading 8414.90.4040, HTS, as you have suggested. However, as the item functions in a manner similar to that of a woodruff key or cotter pin, your suggested classification is deemed inappropriate.

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

A copy of this 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 Kathy Campanelli at 212-637-7025.


Robert B. Swierupski
National Commodity

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