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NY I85201

September 4, 2002

CLA-2-84:RR:NC:1:103 I85201


TARIFF NO.: 8485.90.0080

Mr. Karl F. Krueger
Danzas AEI Customs Brokerage Services
29200 Northwestern Highway
Southfield, MI 48034

RE: The tariff classification of grease fittings from England

Dear Mr. Krueger:

In your letter dated July 31, 2002 on behalf of the Plews/Edelmann Division of Epicor Industries you requested a tariff classification ruling.

Descriptive information and samples of various grease fittings were included with your request. The imported fittings will be used as lubrication fittings on various machines and bearings, and are available in various sizes and in both straight and angled configurations. They basically consist of a mild steel or stainless steel body attached to a threaded shank for ease of installation. The body incorporates an orifice containing a heat-treated spring and a ball check which prevents dirt from entering the orifice through which lubricant will flow. Mild steel hydraulic fittings will be manufactured from nickel-chrome steel, will be case hardened to prevent wear at the tip, and will be zinc plated for maximum corrosion resistance. Stainless steel hydraulic fittings will be used for the lubrication of bearings in hostile environments.

In your letter you contended that, since they allow hydraulic flow in only one direction, they are check valves classifiable in subheading 8481.30.2090, Harmonized Tariff Schedule of the United States (HTS), which provides for check (nonreturn) valves of steel.

The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official interpretation of the Harmonized System at the international level. While not legally binding, the ENs provide a commentary on the scope of each heading of the Harmonized Tariff Schedule of the United States (HTS) and are generally indicative of the proper interpretation of these headings. In classifying goods, Customs believes the ENs should always be consulted (see T.D. 89-80). The ENs for heading 84.81 state that “certain machinery parts which incorporate a complete valve, or which regulate the flow of a fluid inside a machine although not forming a complete valve in themselves, are classified as parts of the relative machines, for example.non-automatic greasing nipples (heading 84.85)”. The ENs for heading 84.85 state that this heading covers goods which are recognized as being parts of machines, but not as parts of any particular machine, such as greasing nipples.

Based on the above, the grease fittings are not classifiable in subheading 8481.30.2090, HTS. The applicable subheading for the grease fittings will be 8485.90.0080, HTS, which provides for machinery parts not containing electrical connectors, insulators, coils, contacts or other electrical features, and not specified or included elsewhere (in chapter 84): other: other. The rate of duty will be 3.9 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 Alan Horowitz at 646-733-3010.


Robert B. Swierupski

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