CBP Ruling N132561 — The tariff classification of a brake fluid reservoir cap from Japan

Tariff classification

Headings: 8413

Product description

Descriptive literature and pictures were included with your submission. The article in question is described as a brake fluid reservoir cap, part number 4625A380. You indicate that the reservoir cap is specifically designed as a service part for Mitsubishi automobiles. It is made of polypropylene (plastic) and includes a rubber seal. The purpose of the cap is to cover the master cylinder brake fluid reservoir in order to prevent pressurized hydraulic fluid from spilling/leaking during normal vehicle operation. You suggest classification of the reservoir cap under subheading 8708.30.5090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts … of … motor vehicles … : Brakes and servo-brakes; parts thereof: For other vehicles: Other." Although the subject cap is, prima facie, a component of a vehicle’s braking system, we find that it is more specifically provided for as part of the master cylinder reservoir which holds the brake fluid. Master cylinder reservoirs were previously ruled upon in New York Ruling N109341 as parts of hydraulic pumps under HTSUS subheading 8413.91.

CBP rationale

The applicable subheading for the brake fluid reservoir cap will be 8413.91.9050, HTSUS, which provides for parts of hydraulic fluid power pumps.

Full text

N132561 December 14, 2010 CLA-2-84:OT:RR:NC:N1:102 CATEGORY: Classification TARIFF NO.: 8413.91.9050 Mr. Ralph Garcia Mitsubishi Motors North America Inc. 6400 Katella Ave. Cypress, CA 90630 RE: The tariff classification of a brake fluid reservoir cap from Japan Dear Mr. Garcia: In your letter dated November 12, 2010 you requested a tariff classification ruling. Descriptive literature and pictures were included with your submission. The article in question is described as a brake fluid reservoir cap, part number 4625A380. You indicate that the reservoir cap is specifically designed as a service part for Mitsubishi automobiles. It is made of polypropylene (plastic) and includes a rubber seal. The purpose of the cap is to cover the master cylinder brake fluid reservoir in order to prevent pressurized hydraulic fluid from spilling/leaking during normal vehicle operation. You suggest classification of the reservoir cap under subheading 8708.30.5090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts … of … motor vehicles … : Brakes and servo-brakes; parts thereof: For other vehicles: Other." Although the subject cap is, prima facie, a component of a vehicle’s braking system, we find that it is more specifically provided for as part of the master cylinder reservoir which holds the brake fluid. Master cylinder reservoirs were previously ruled upon in New York Ruling N109341 as parts of hydraulic pumps under HTSUS subheading 8413.91. The applicable subheading for the brake fluid reservoir cap 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

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