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NY N006160

March 1, 2007



TARIFF NO.: 8412.21.0075, 8413.81.0040

Mr. Matthew K. Nakachi
Sandler, Travis & Rosenberg and Glad & Ferguson, P.C.
505 Sansome Street (Suite 1475)
San Francisco, CA 94111

RE: The tariff classification of master and slave cylinders from Mexico

Dear Mr. Nakachi:

In your letter dated January 25, 2007 you requested a tariff classification ruling on behalf of your client FTE Automotive.

The articles in question are described as master cylinders, slave cylinders and concentric slave cylinders for use in automotive hydraulic systems. The master cylinders are pedal actuated piston pumps that convert mechanical force into fluid power by pressurizing hydraulic fluid within a hydraulic system. The slave cylinders are linear actuators that convert pressurized fluid within the hydraulic system into mechanical energy. Descriptive information and photographs were submitted.

In your request you aver that the master cylinders are properly classified in heading 8413, Harmonized Tariff Schedule of the United States (HTSUS), which provides for liquid pumps, and that the slave and concentric slave cylinders are provided for in HTSUS heading 8412, which provides for hydraulic power engines and motors. Based on the information you have made available, we agree that the master cylinders are liquid pumps and that the slave cylinders are linear hydraulic motors.

The applicable subheading for the master cylinders will be 8413.81.0040, HTSUS, which provides for other liquid pumps. The rate of duty is free.

The applicable subheading for the slave cylinders will be 8412.21.0075, HTSUS, which provides for other linear acting hydraulic power engines and motors. The rate of duty is free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Kenneth T. Brock at 646-733-3009.


Robert B. Swierupski

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