CLA-2-87:RR:NC:MM:101 H88185
Mr. Mitchell Neriah
Mitchell Neriah Customs Consulting Services
415 S. Prospect Ave., Suite 110
Redondo Beach, California 90277
RE: The tariff classification of Various Components (“SLIDE INNER RAIL”, “SLIDE OUTER RAIL”, “WIRE COMP”, “MANUAL RECLINER”, and “SPIRAL SPRING”) from Japan
Dear Mr. Neriah:
In your letter dated January 30, 2002 you requested a tariff classification ruling on behalf of Imasen Bucyrus Technology, Inc. (“IB Tech).
You submitted and photographs of various components of seat adjusting mechanisms and seats used in motor vehicles. You state that the complete seat adjusting mechanism is referred to by IB Tech as a “Full Seat Device.” The Full Seat Device is the entire base metal assembly upon which the seat is mounted, and allows for the seat occupant to adjust the seat position forward or reverse, adjust the seat back recline position, and in some cases, raising or lowering seat height in relation to the auto floor. The seat back and the seat bottom are attached to the Full Seat Device, and the Full Seat Device is fastened to the floor by a bracket. In your narrative you state the following:
The first item, “SLIDE INNER RAIL”, is a component of the Full Seat Device. The Slide Inner Rail is used on a Full Seat Device which adjusts the seat position manually rather than by electric motor. The Slide Inner Rail is a base metal assembly, with an inner slotted track for engaging a locking mechanism, a spring loaded handle lock/release mechanism, and a top slide bracket which mounts to the auto seat bottom. The occupant pulls the handle, releasing a locking mechanism along the slotted track, and allows the seat to slide forward or reverse. The slide Inner Rail is attached to the auto floor by a separate bracket (called a “Foot”), and to the seat bottom. You state that the Slide Inner Rail is specifically designed for and used solely with automobile seats.
The second item, “SLIDE OUTER RAIL”, is a component of the Full Seat Device. The Slide Outer Rail is used on a Full Seat Device which adjusts the seat position manually rather than by electric motor. The Slide Inner Rail is a base metal assembly, with an inner slotted track for engaging a locking mechanism, a spring loaded handle lock/release mechanism, and a top slide bracket which mounts to auto seat bottom. The Slide Outer Rail is always used with the Slide Inner Rail, one on each side, to assemble the Full Seat Device. The Slide Outer Rail is attached to the auto floor by a separate bracket (called a “Foot”), and to the seat bottom. Unlike the Slide Inner Rail, the slide Outer Rail does not have a handle release for the locking mechanism. The locking mechanism is released by connecting the release handle on the Slide Inner Rail to the locking mechanism on the Slide Outer Rail by a wire assembly. The wire assembly is called a “WIRE COMP”, the third subject of this ruling request. You state that the Slide Outer Rail is specifically designed for and used solely with automobile seats.
The third item, “WIRE COMP”, is a steel wire with a loop on each end. The wire loop ends are secured with a metal grommet. The wire is used on the manually operated Full Seat Device and the slide rails described above. The Wire Comp attaches between the locking mechanism in the Slide Outer Rail to release the handle in the Slide Inner Rail. As the handle is turned, the wire pulls and releases the locking mechanism from the slots in the Slide Outer Rail. You state that the Wire Comp is specifically designed for and used solely with automobile seats.
The fourth and fifth items, “MANUAL RECLINER” and “SPIRAL SPRING” are parts of manually operated seat recline position adjusters. The Manual recliner is a base metal assembly with a center turning mechanism to which an outside handle is attached on the protruding shaft. On the inside is a cam which rotates with the shaft as the outer handle is pulled. Around the cam is a flange which supports the Spiral spring. The Spiral Spring is placed on the Manual Recliner, so that the inner end of the Spiral Spring rests between the flange and the cam which is turned by the outer handle. When the handle is pulled, the cam is turned, and pulls the spring so that the centripetal spring pressure is abated. This allows the back seat to swivel along a shaft in the seat, thus raising or lowering the incline of the seat back. When the handle is released, the spring flexes back outward, causing enough pressure to lock the seat back in position. The Manual recliner is not part of a Full Seat Device. The Manual Recliner is assembled as part of an automobile seat, and is bolted to and welded to the seat back frame.
The applicable subheading for SPIRAL SPRING the will be 7320.90.5060, Harmonized Tariff Schedule of the United States (HTS), which provides for Springs and leaves for springs, of iron or steel: Other: Other…Other. The rate of duty will be 2.9% ad valorem.
The applicable subheading for the SLIDE INNER RAIL, SLIDE OUTER RAIL, and WIRE COMP will be 8708.29.5060, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories of bodies (including cabs): Other: Other…Other. The rate of duty will be 2.5% ad valorem.
The applicable subheading for MANUAL RECLINER the will be 9401.90.1080, Harmonized Tariff Schedule of the United States (HTS), which provides for Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Parts: Of seats of a kind used for motor vehicles…Other. The rate of duty will be Free.
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 646-733-3008.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division