The tariff classification of piston parts from Japan

N108416 June 30, 2010 CLA-2-84:OT:RR:NC:N1:102 CATEGORY: Classification TARIFF NO.: 8413.91.9050 Ms. Nicole M. Jenkins Crowell & Moring LLP 1001 Pennsylvania Avenue, NW Washington, DC 20004 RE: The tariff classification of piston parts from Japan Dear Ms. Jenkins: In your letter dated June 3, 2010 you requested a tariff classification ruling on behalf your client, Aisin Holdings of America, Inc. The articles in question are described as piston parts, part numbers 132211-60070, 132232-10020 and 13221-80150. You indicate in your request that while the detailed specifications provided are for part number 132211-60070, each of the identified parts are functionally identical. A schematic drawing of piston part number 132211-60070, was also included with your submission. You state that the primary function of the piston parts is to create hydraulic pressure within the master cylinder of an automobile's brake booster which enables the vehicle to brake. Brake booster assemblies were previously ruled upon in New York Ruling N014493 as other reciprocating positive displacement pumps for hydraulic fluid in subheading 8413.50.0080, Harmonized Tariff Schedule of the United States (HTSUS). The brake booster is comprised of several components, including a hydraulic booster, an accumulator and a master cylinder that is separated into two chambers by a primary piston and a secondary piston. When the brake pedal is depressed, an electric motor within the booster drives a piston pump to discharge hydraulic fluid into an accumulator. The increased hydraulic pressure within the accumulator is then used to drive the primary and secondary pistons within the master cylinder forcing hydraulic fluid into the brake lines to actuate the vehicle's brakes. Based on the information submitted, the subject piston parts are integral components of the mechanism used in positive displacement piston pumps used to provide fluid power in hydraulic systems. The applicable subheading for the piston parts will be 8413.91.9050, HTSUS, which provides for parts of hydraulic fluid power pumps. 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. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division