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D88533: The tariff classification of pipette parts from France
Ruling Date: Mar 19, 1999
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NY D88533


March 19, 1999

CLA-2-84:RR:NC:1:103 D88533

CATEGORY: Classification

TARIFF NO.: 8479.90.9595; 7320.20.5020

Mr. Mark S. Septimus
EIX Corporation
9009 Western Lake Drive #1410
Jacksonville, FL 32256

RE:    The tariff classification of pipette parts from France

Dear Mr. Septimus:

    In your letter dated February 19, 1999 you requested a tariff classification ruling.

    In previous ruling letters issued to you we provided tariff classification information on certain components of mechanical pipettes. You have now advised us that some of these components are available in various sizes, depending on the pipette model in which they will be used.

    A mechanical pipette is a hand held laboratory appliance which utilizes a piston assembly, along with a micrometer which adjusts the piston stroke, to draw and dispense precise volumes of liquids. Your firm intends to import replacement parts for use in the repair of Gilson Pipetman® pipettes. Depending on the model, these pipettes can draw liquid volumes ranging from .1 microliter to 5 milliliters. The parts will be manufactured by Gilson in France, but may be exported from another country. You stated that neither the parts nor their packaging bear any trademark, patent or copyright information.

    In Ruling Letter D86634 of Feb. 9, 1999 we advised you as to the classification of a stainless steel tip ejector 5.25 inches long for a model P-200 pipette. Your current letter states that this tip ejector is also made in a version 4.75 inches long for pipette models P-2, P-10, P-20, and P-100, as well as a version 6.25 inches in length which fits the model P-1000.

    In that same ruling letter we provided the classification of a model P-100 seal assembly holder, which we described as a plastic ring with a groove on one side and four small tabs on the other side. Your letter advises us that the seal assembly holder for the model P-200 has a groove on one side but lacks any tabs on its reverse side. Two other sizes of seal assembly holders (one for models P-2 and P-10, and one for the P-20) are short plastic cylinders with six ridges on one side.
    In Ruling Letter D86635 of Feb. 9, 1999 we described a small stainless steel spring 3/4 inch in length for use in pipette models P-2 and P-10. You now indicate it is also available in a version one inch long for pipette models P-20, P-100, and P-200.

    Finally, in Ruling Letter D86633 of Feb. 9, 1999 we described a large stainless steel spring two inches in length for use as a part of model P-100 and P-200 pipettes. You state that, for models P-2, P-10, and P-20, this spring is 1 and 5/8 inches in length.

    The applicable subheading for the tip ejectors which are 4.75 inches or 6.75 inches long, as well as for the seal assembly holders described above, will again be 8479.90.9595, Harmonized Tariff Schedule of the United States (HTS), which provides for parts of machines and mechanical appliances having individual functions, not specified or included elsewhere (in chapter 84): other: other: other. The rate of duty will be free.

    The applicable subheading for the one inch long small spring and the 1 and 5/8 inches long large spring will again be 7320.20.5020, HTS, which provides for springs and leaves for springs, of iron or steel: helical springs: other: helical springs, of wire having a cross-sectional dimension of less than 5.1 mm: other. The rate of duty will be 3.9 percent ad valorem.

    You may address any questions regarding trademark issues incident to the importation of these goods to the Intellectual Property Rights Branch, U.S. Customs Service, 1300 Pennsylvania Avenue, NW, Washington, DC 20229.

    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 Alan Horowitz at 212-637-7027.


                        Sincerely,


                        Robert B. Swierupski
                        Director,
                        National Commodity
                        Specialist Division