CLA-2-85:RR:NC:MM:109 J87417

Mr. Harold Averill
Attorney- In-Fact
Corrigan Dispatch Company
Box # 3610
1350 Cheers Boulevard
Brownsville, TX 78525-3610

RE: The tariff classification of Memory Seat Sensors from an Unspecified Country

Dear Mr. Averill:

In your letter dated July 8, 2003, you requested a tariff classification ruling on behalf of CTS Corporation In Texas of Brownsville, Texas.

The merchandise is described in your letter as Memory Seat Sensors. There are two series of these Memory Seat Sensors: Series 505 and Series 240. Each of these products is designed for use in an automobile to position the driver’s seat to a preset position. SERIES 505 - The sensors in the 505 Series contain a potentiometer. The potentiometer is not the wire wound variable resistor type. It is a printed conductive polymer thick film element resistor, which changes in voltage as the sensor’s shaft turns. The 505 Series sensors also consist of a multiple gear drive arrangement (planet, follower, housing, carrier, and contactor plate) to give 485 turns on the drive shaft from one end to the other. The contactor, element leads and terminal pins provide for the electrical connection to the customer’s connector. A cover provides for a mounting interface.

The sensor attaches to the motor located on the seat track within an automobile and is designed to memorize the seat position of two drivers. Each driver adjusts the seat to his or her desired position and then pushes a button assigning that seat position to them. The seat position sensor memorizes the seat position for each driver. When either driver sits in the driver’s seat and pushes the button corresponding to him or her, the sensor sends a signal to activate the motor to position the seat accordingly.

SERIES 240 - The sensors in the 240 Series contain a hall-effect chip mounted onto a printed circuit board. The 240 Series sensors also consist of a magnet, pole pieces, shaft, and retainer clip to provide the means to switch the chip and provide a pulse count. The printed circuit board provides the means to hold the hall-effect chip and make electrical connection to the terminal pins. The terminals provide electrical connection to the customer’s connector. A cover provides for mounting of the unit.

The sensor attaches to the motor located on the seat track within an automobile and is designed to memorize the seat position of two drivers. Each driver adjusts the seat to his or her desired position and then pushes a button assigning that seat position to them. The seat position sensor memorizes the seat position for each driver. When either driver sits in the driver’s seat and pushes the button corresponding to him or her, the sensor sends a signal to activate the motor to position the seat accordingly.

A sample of each of the sensors was submitted to this office and has been returned to you as per your request.

The applicable subheading for the Memory Seat Sensor (Series 505) will be 8533.40.8070, Harmonized Tariff Schedule of the United States (HTS), which provides for “Other variable resistors, including rheostats and potentiometers: Other: Other: Other.” The rate of duty will be free.

The applicable subheading for the Memory Seat Sensor (Series 240) will be 8543.89.9695, Harmonized Tariff Schedule of the United States (HTS), which provides for “”Other electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter…Other machines and apparatus: Other: Other: Other: Other.” The rate of duty will be 2.6 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 Linda M. Hackett at 646-733-3015.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division