CLA-2-39:OT:RR:NC:N4:421
Ms. Nicole Jenkins
Crowell & Moring LLP
1001 Pennsylvania Avenue, NW
Washington, DC 20004-2595
RE: The tariff classification of roller assemblies from Japan
Dear Ms. Jenkins:
In your letter dated July 6, 2010, on behalf of Aisin Holdings of America, Inc., you requested a tariff classification ruling.
Samples identified as upper and lower roller assemblies were provided with a previous letter. The components function to support and guide the sliding side door of a van. The assemblies facilitate the outward and rearward motion of the van door as it slides open and the inward and forward motion of the van door as it slides closed. The upper and lower roller assemblies are attached onto the upper or lower portion of the door respectively, and move on tracks attached to the body of the vehicle. The upper roller assembly, Part no 424441-10060-A, is composed of a plastic roller measuring approximately 7/8 inch in outer diameter with a copper inner ring and a steel side support. The lower roller assembly, Part 424643-10080, is composed of a polyamide plastic roller measuring approximately 3/4 inch in outer diameter with a plastic inner ring. The roller assemblies are imported without an attached shaft.
You suggest classification of the roller assemblies in heading 8302 of the Harmonized Tariff Schedule of the United States (HTSUS) as mountings and fittings suitable for coachwork. This office agrees with your position that the assemblies are not classifiable as parts of vehicles of Section XVII or parts of articles of Section XVI because of the exclusions from those Sections of parts of general use, as defined in Note 2, Section XV, and similar goods of plastics. This office also agrees that the roller assemblies are mountings and fittings for coachwork. However, heading 8302 is limited to goods with an essential character of base metal. Part 424643-10080 is constructed entirely of plastics and does not contain any metal. Therefore, this assembly cannot be classified in heading 8302 and is instead classified in the comparable provision for such articles when made of, or having an essential character of, plastics.
The applicable subheading for the lower roller assembly, Part 424643-10080, will be 3926.30.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics…fittings for furniture, coachwork or the like: other. The rate of duty will be 5.3 percent ad valorem.
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/.
Your inquiry does not provide enough information for us to give a classification ruling on the upper roller assembly, Part 424441-10060-A. Although the sample consists of a plastic roller with a copper inner ring and steel side plate, the only metal component listed in the weight and cost breakdowns submitted with your request is copper. Your request for a classification ruling should include a component material breakdown by weight and value that addresses each component in the assembly. Also, provide any evidence that might support your position that the metal components impart the essential character. When this information is available, you may wish to consider resubmission of your request. If you decide to resubmit your request, please include copies of all relevant documentation and correspondence, including your original and subsequent letters, this ruling, and previous rejection letters from this office.
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 Joan Mazzola at (646) 733-3023.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division