CLA-2-87:S:N:N1:101-859234

Mr. Mike Dowson
Lec-Triks
Box 151 L7R 3Y2
Burlington, Ontario, Canada

RE: The tariff classification of electric window regulators for automobiles, manual window regulators for automobiles, window glass channels, insulation material, and sound deadener material from Canada

Dear Mr. Dowson:

In your letter dated December 20, 1990 you requested a tariff classification ruling.

The first item which you submitted is an electric window regulator for automobiles. This product is used to convert standard automobile windows to electric power windows. The item consists of an electric motor with a guide attachment which is used to lift and lower the automobile window. You have informed our Buffalo District that the motor is a 12 Volt, one Amp DC motor with a power output of 12 Watts.

The second item is a manual window regulator for automobiles. This product is used to replace worn out window regulators.

The third item is a window glass channel which attaches the window glass to either the electric or manual window regulator.

The fourth item is sound deadener material which consists of reclaimed polyvinylchloride (PVC) sheet. This material is applied to the interior panels of doors and trunk lids to insulate against sound transmission. The material is imported in 5 foot by 6 foot rolls and is not cut to size to fit any particular automobile.

The fifth item is the sound deadener material of item four which is bonded to polyurethane foam. This combination sound deadener/foam insulation is used on the firewall, floor, and trunk of the automobile. It is imported in 8 foot by 6 foot rolls, and is not cut to size to fit any particular automobile. The applicable subheading for the electrical window regulator mechanism will be 8501.10.4040, Harmonized Tariff Schedule of the United States (HTS), which provides for other brushless DC motors of an output not exceeding 37.5 Watts. The rate of duty will be 6.6 percent ad valorem.

The applicable subheading for the manually operated window regulator mechanism will be 8302.30.3000 which provides for other mountings, fittings and similar articles of iron or steel, of aluminum or of zinc suitable for motor vehicles. The rate of duty will be 3.1 percent ad valorem.

The applicable subheading for the window channel will be 8302.30.3000 which provides for other mountings, fittings and similar articles of iron or steel, of aluminum or of zinc suitable for motor vehicles. The rate of duty will be 3.1 percent ad valorem.

The applicable subheading for the sound deadener material will be 3920.42.5000 which provides for other plates, sheets, film, foil and strip of plastics, noncellular and not reinforced, laminated, supported or similarly combined with other materials, of polymers of vinyl chloride, flexible, other. The rate of duty will be 4.2 percent ad valorem.

The applicable subheading for the sound deadener material bonded to foam will be 3921.13.5000 which provides for other plates, sheets, foil and strip, of plastic, cellular, of polyurethane, other. The rate of duty will be 4.2 percent ad valorem.

Goods classifiable under the following subheading, which originated in the territory of Canada, will be entitled to the rate of duty as indicated below, under the United States-Canada Free Trade Agreement upon compliance with all applicable regulations:

Subheading Rate of duty

8501.10.4040 4.6 percent ad valorem 8302.3030000 2.1 percent ad valorem 3920.42.5000 2.9 percent ad valorem 3921.13.5000 2.9 percent ad valorem

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Sincerely,

Jean F. Maguire
Area Director
New York Seaport