CLA-2-83:RR:NC:N1:113 J81646
Mr. Spiro Karras
Sandler & Travis Trade Advisory Services, Inc.
38345 Ten Mile Road
Farmington Hills, Michigan 48335
RE: The tariff classification of door locks and latches from France and Germany.
Dear Mr. Karras:
In your letter dated February 26, 2003, you requested a ruling on behalf of Volkswagen of America on tariff classification.
The samples you provided are four door locks and latches. Parts # 8B1837016D and #8D1837016F are for use with vehicles that have electronic door locks or a radio control central locking system. They can be activated by insertion of a key into the door, by activation of a locking switch from within, or by a keyless remote.
Parts #701837016E and #443837015L are described as door latches. Each lock has a lever that flips onto the striker plate on the B pillar so that the door will not open. In your letter, you discuss the difference between a lock and a latch. Basically, a lock is defined in the Explanatory Notes as operating by means of a key, a combination, by insertion of a magnetic card, by entering data on an electronic keyboard, or by radio wave signal. It appears from your schematic that the latches are attached to the locking mechanism by means of a cable. They can be opened by the action of the key.
The applicable subheading for this product will be 8301.20.0060, Harmonized Tariff Schedule of the United States (HTS), which provides for locks of a kind used on motor vehicles. The general rate of duty will be 5.7 percent ad valorem.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R.).
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 James Smyth at 646-733-3018.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division