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NY N016737

October 3, 2007



TARIFF NO.: 8413.20.0000

Ms. Latrice Hogan
Grainger International, Inc.
100 Grainger Parkway
Lake Forest, IL 60045-5201

RE: The tariff classification of a hydraulic ram system from Taiwan

Dear Ms. Hogan:

In your letter dated August 31, 2007 you requested a tariff classification ruling.

The article in question is described as a 10 ton hydraulic ram system. The ram system is a set containing a manually operated hydraulic piston pump, a hydraulic cylinder (ram), pressure hose, various size extension rods for mounting on the ram, and a number of work attachments (spreader, flat base, ram toe, combination head, rubber head, etc.). These items are imported together, and sold at retail, in a plastic storage case.

Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is governed by the General Rules of Interpretation (GRIs). GRI 3 provides for the classification of "goods put up in sets for retail sale" ("sets"). Sets for tariff purposes consist of at least two different articles which are, prima facie, classifiable in different headings. The hydraulic ram system satisfies this description. The system consists of a hydraulic pump classifiable within heading 8413, HTSUS, a hydraulic cylinder classifiable within heading 8412, HTSUS, and various other items that are classified in headings other than HTSUS heading 8412 or 8413.

GRI 3(a) states that the heading which provides the most specific description of a set shall be preferred to headings providing a more general description. However, when two or more headings each refer to part only of the items in a set, those headings are to be regarded as equally specific in relation to those goods, even if one of them gives a more complete or precise description of the goods. Accordingly, the kit is not classifiable by the application of GRI 3(a).

GRI 3(b) provides that sets which cannot be classified by reference to GRI 3(a) shall be classified as if they consisted of the component which gives them their essential character. In this case, we find that the hand-operated hydraulic pump is the component which gives the set its essential character. Therefore, based upon the application of GRI 3(b), the subject set is classifiable as if it consisted solely of the hydraulic pump.

The applicable subheading for the hydraulic ram system will be 8413.20.0000, HTSUS, which provides for hand pumps, other than those of subheading 8413.11 or 8413.19. 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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