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NY H88655

March 5, 2002

CLA-2-84:RR:NC:1:104 H88655


TARIFF NO.: 8412.21.0075; 8454.90.0030

Ms. Tammie Goldstein Krauskopf
Katten Muchin Zavis
525 West Monroe Street
Suite 1600
Chicago, IL 60661-3693

RE: The tariff classification of a hydraulic cylinder, spline core, slide core and impression steel for die casting dies from Japan

Dear Ms. Goldstein Krauskopf:

In your letter dated February 11, 2002 on behalf of Ryobi Die Casting USA, Inc. you requested a tariff classification ruling.

A die cast die is a mold which has molten material injected into it by a die cast machine at a high velocity and pressure in order to produce an article in a defined shape and dimension. The molten material solidifies and the casted article is ejected from the die. Each die cast die is composed of a number of moveable and replaceable parts. These parts are unique to that specific die and are not interchangeable. Several of these parts are the subject of this letter.

The hydraulic cylinder is used to move slide cores (and other movable parts of the die) during the die casting process. The cylinder is fed by the die cast machine’s hydraulic system.

The spline core is a type of replaceable die insert used to form a large section of the casting, similar to the slide cores. It is used to form a more complex section of a casting, typically where clutch packs are fitted. Molten material flows between the spline and slide cores to form the wall of the casting.

The slide core is a movable part of the die used to create the outer surface or walls of the casting. The core(s) slides into place forming the shape of the casting. Molten material is then injected into the cavity created by the slides to form the casting.

The impression steel is the entire segment of steel which forms the die cavity and, thus, the casting’s external and internal shape. Certain components of the die cast die (e.g., ejector pins, core pins and cover slides) may be mounted onto the impression steel to further define the shape of the casting.

A complete die cast die (mold) is classifiable under heading 8480, Harmonized Tariff Schedule of the United States (HTS), which provides for molds. However, even though the parts in question are designed and dedicated for use solely with a particular mold, they cannot be classified under heading 8480, HTS, as there is no provision for parts or accessories of molds under that specific heading. Rather they are to be classified in accordance with the applicable section and chapter notes.

Note 2 to section XVI states that, subject to certain exclusions found in note 1 to section XVI, note 1 to chapter 84 and note 1 to chapter 85, parts of machines (not being parts of the articles of heading 8484, 8544, 8545, 8546 or 8547) are to be classified according to the following rules: (a) Parts which are goods included in any of the headings of chapters 84 and 85 (other than headings 8409, 8431, 8448, 8466, 8473, 8485, 8503, 8522, 8529, 8538 and 8548) are in all cases to be classified in their respective headings; (b) Other parts, if suitable for use solely or principally with a particular kind of machine, or with a number of machines of the same heading (including a machine of heading 8479 or 8543) are to be classified with the machines of that kind or in heading 8409, 8431, 8448, 8466, 8473, 8503, 8522, 8529 or 8538 as appropriate.. However, parts which are equally suitable for use principally with the goods of headings 8517 and 8525 to 8528 are to be classified in heading 8517; (c) All other parts are to be classified in heading 8409, 8431, 8448, 8466, 8473, 8503, 8522, 8529 or 8538 as appropriate or, failing that, in heading 8485 or 8548.

The applicable subheading for the hydraulic cylinder will be 8412.21.0075, Harmonized Tariff Schedule of the United States (HTS), which provides for Other engines and motors, and parts thereof: Hydraulic power engines and motors: Linear acting (cylinders)Other: Other. The rate of duty will be Free.

The applicable subheading for the spline core, slide core and impression steel will be 8454.90.0030, HTS, which provides for Converters, ladles, ingot molds and casting machines, of a kind used in metallurgy or in metal foundries, and parts thereof: PartsOf casting machines: Of die casting machines. The rate of duty will be Free.

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 Losche at 646-733-3011.


Robert B. Swierupski

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