CLA-2-87:RR:NC:MM:101 C89088
Mr. Carlos R. Juelle
Stein, Shostak, Shostak & O'Hara
Suite 1200
515 Figueroa Street
Los Angeles, California 90071-3329
RE: The tariff classification of steel guide clips and plastic
sunroof knobs from Japan.
Dear Mr. Juelle:
In your letter dated June 30, 1998 you requested a tariff
classification ruling on behalf of your client, Aisin World
Corporation of America in Torrance California.
The first item is a steel spring type guide which keeps the
automotive sunroof straight when it is being opened and closed.
The second item is a plastic sunroof knob which is used to
manually open and close the sunroof.
You have suggested that the correct classification for both
items would be 8708.29.5060 which provides for other body parts.
Section XVII of the Harmonized Tariff Schedule of the United
States (HTS) indicates in Note 2 (b): "The expressions parts'
and parts and accessories' do not apply to the following
articles, whether or not they are identifiable as for the goods
of this section: (b) Parts of general use, as defined in note 2
to section XV, of base metal (Section XV) or similar goods of
plastics (chapter 39)."
Section XV Note 2 (c) indicates: "Throughout the tariff
schedule, the expression parts of general use' means:(c)
Articles of heading 8301, 8302, 8308, or 8310 and frames and
mirrors of base metal, of heading 82306."
Subheading 8302.30 (HTS) applies to: "Base metal mountings,
fittings and similar articles suitable for furniture, doors,
staircases, windows, blinds, coachwork, saddlery, trunks, chests,
caskets or the like; base metal hat racks, hat-pegs, brackets and
similar fixtures; castors with mountings of base metal; automatic
door closers of base metal; and base metal parts thereof:..Other
mountings, fittings and similar articles suitable for motor
vehicles; and parts thereof.."
It is our opinion that the spring clip guides and knobs are
fittings in the meaning of Subheading 8302.30(HTS). The guides
are of base metal and should be classified in Heading 8302. The
knobs are plastic, but are similar to the goods described in
Heading 8302, and should therefore be classified in Chapter 39
(HTS).
The applicable subheading for the spring clip guides will be
8302.30.3060, Harmonized Tariff Schedule of the United States
(HTS), which provides for base metal mountings, fittings and
similar articles suitable for furniture, doors, staircases,
windows, blinds, coachwork...Other mountings fittings and similar
articles suitable for motor vehicles; and parts thereof: Of iron
or steel, of aluminum or of zinc...Other.. The rate of duty will
be 2.2 percent ad valorem.
The applicable subheading for the plastic sunroof knobs will
be 3926.30.1000, Harmonized Tariff Schedule of the United States
(HTS), which provides for other articles of plastics and articles
of other materials of headings 3901 to 3914...Fittings for
furniture, coachwork or the like: Handles and knobs. The rate of
duty will be 6.5 percent ad valorem.
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 Robert
DeSoucey at 212-466-5667.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division