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NY N020275

December 18, 2007



TARIFF NO.: 4016.99.3500

Ms. Laurie Arnold
JAS Forwarding (USA) Inc.
575 Forest Parkway
Suite A
Atlanta, GA 30349

RE: The tariff classification of rubber coupling elements from Germany, India or China

Dear Ms. Arnold:

In your letter dated November 20, 2007, on behalf of American Vulkan Corporation, you requested a tariff classification ruling.

A sample piece of a rubber coupling element was included with your request. After importation the elements are combined to form couplings for marine and industrial applications. The couplings are used for connections between a diesel engine and component such as gear box, generator or drive shaft, in installations requiring a high level of torsional flexibility and misalignment capacity. The couplings transmit torque and reduce noise and vibration. The coupling elements are composed of rubber with metal flanges. The metal flanges facilitate the mounting of the rubber elements within the mechanical coupling. The rubber functions to reduce noise, vibration and misalignment, and is thus the component that contributes to the function of the couplings. The essential character is imparted by the rubber. You have submitted information confirming that the rubber is natural isoprene rubber.

The applicable subheading for the rubber coupling elements will be 4016.99.3500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of vulcanized rubber other than hard rubber: of natural rubber: other. The rate of duty will be 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 Joan Mazzola at 646-733-3023.


Robert B. Swierupski

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