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NY J86515

July 14, 2003

CLA-2-90:RR:NC:N1:105 J86515


TARIFF NO.: 9031.80.8085

Mr. Len Kreusler
Global Fairways
373 N. Wood Dale Road
Wood Dale, IL 60191

RE: The tariff classification of a Leak Device System from Germany

Dear Mr. Kreusler:

In your letters dated April 21 and June 16, 2003, for Cooper Tools, you requested a tariff classification ruling. No samples were submitted.

Cooper Automation’s letter of June 6, 2003, describes the item: “This machine is a station on an integrated assembly line that assembles and tests power assisted steering gear assemblies for the WK-Klasse Jeep Cherokee and the Mercedes M-Klasse SUV. The rack tube consists of a casting with a piston that has been assembled inside and is sealed at both ends. There is a valve tube that extends near vertically off of the rack tube. There are two fittings on the valve tube that allow pressure to be applied from the master brake cylinder. Depending on the alignment of the rotary valve inside the valve tube, pressure will be applied to either side of the piston to make the piston move more easily to the right or left thus extending the tie rod to the left or the right. In operation, when the steering wheel is turned, the rack inside the rack tube is mechanically moved and pressure is applied to either side of the piston providing the power assist for ease of turning.

The steering gear assembly is located and positioned on a pallet that travels down an assembly line. As the pallet passes by the test machine, it stops and indexes position. Once positioned, the machine connects to the valve tube via two fittings. This machine in question here then applies a known pressure to each side of the piston and tests for a drop over time. If there is a drop, it signifies a leak in the seals. The machine also applies a vacuum and test for a rise in pressure. This would also signify a leak in the seals. The machine accomplishes this test with air, not fluid. The air is supplied by a central air system that is connected to the machine. The air supply and pressure is regulated at the machine via computer controlled valves. There is no compressor that is part of the machine. The machine has the ability to test steering gear assemblies that are configured for right hand drive vehicles and left hand drive vehicles. In either case, there is a valve tower either on the right side of the rack or the left side of the rack. The rack tube is secured to the pallet by a clamp in the center of the rack tube, and the test is performed either by the right testing device or the left testing device. The testing is performed by a pressure differential device and the cost of this item is 8,000 Euro as represented to Cooper Automation by the German supplier.”

You proposed classification in 9026. However, the apparatus specifically required for the pressure measurement per se is only about 10 % of the total cost of the item, and the import will contain major elements to control the flow of pressurized air into and to manipulate the device under test. The item as a whole does check that the steering gear meets the specification of being leak proof.

The applicable subheading for your item will be 9031.80.8085, Harmonized Tariff Schedule of the United States (HTS), which provides for “other,” non-optical, measuring or checking instruments and appliances. The rate of duty will be 1.7 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 J. Sheridan at 646-733-3012.


Robert B. Swierupski

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