The tariff classification of a seat union from Japan

N118976 September 9, 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 Ave. NW Washington, DC 20004 RE: The tariff classification of a seat union from Japan Dear Ms. Jenkins: In your letter dated August 11, 2010 you requested a tariff classification ruling on behalf of Aisin Holdings of America, Inc. Descriptive literature, a schematic drawing and a photograph were submitted. The article you plan to import is described as a seat union, part number 984151. The union is made of brass and is incorporated into an automobile’s brake booster. Its primary function is to create a seal between the master cylinder body and the brake line to prevent brake fluid from leaking which helps maintain hydraulic pressure. 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. The seat union seals the master cylinder body to the brake line to prevent brake fluid from leaking. The brake line is inserted through the seat union which is secured to the outside of the brake line by internal threads that are crimped around the brake line. The seat union contains a groove that locks it into the master cylinder body creating a seal. You suggest classification of the seat union in either subheading 7412.20.0015, Harmonized Tariff Schedule of the United States (HTSUS), which provides for copper tube or pipe fittings (for example, couplings, elbows or sleeves), of copper alloys for brake hoses for vehicles of subheading 8701.20 or heading 8702, 8703, 8704 or 8705 or in subheading 8413.91, HTSUS, which provides for parts of pumps. The seat union is incorporated into a type of pump (i.e. brake booster) and creates a seal between the master cylinder body and the brake line. The seal prevents brake fluid from leaking and helps maintain hydraulic pressure within the master cylinder in order for the brake booster to operate properly. As such, we find that the seat union is an integral component used in positive displacement piston pumps to provide fluid power in hydraulic systems and is more specifically provided for as a pump part than a fitting of HTSUS heading 7412. The applicable subheading for the seat union 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