CLA-2-83:OT:RR:NC:N1:121
Ms. Laurie Peach
American Honda Motor Co., Inc.
1919 Torrance Boulevard
Torrance, CA 90501-2746
RE: The tariff classification of lock assemblies from Japan
Dear Ms. Peach:
In your letter dated September 26, 2008, you requested a tariff classification ruling. The samples which you submitted are being returned as requested.
The merchandise under consideration is three assemblies used on certain Honda automobiles.
Part number 72110-SK7-A02 is described as a “Lock Assy., R. FR. Power Door.” It is made of steel, plastic, brass and rubber. Its main components are a latch body that includes a release mechanism and a controlling mechanism, an outer door handle connecting rod, a key cylinder rod, switch and wiring harness. The release mechanism functions to release the latch hook from the striker (i.e. to open the door) and is actuated by manual operation of either the outer or inner door handles. The controlling mechanism interacts with the release mechanism to either allow or to prevent the operation of the release mechanism. This lock assembly does not include a key cylinder, an electronic actuator, outer and inner door handles nor an inner door handle connecting rod.
Part number 76410-SA2-003 is described as a “Lock Assy., R. RR. Door.” It is made of steel, plastic, brass and rubber. Its main components are a latch body and an inside lock knob connecting rod. As imported, the latch assembly includes a single attached rod which connects the assembly to the outside door handle of the rear door. The controlling mechanism within this assembly is activated only by manipulation of the interior lock knob. It is not designed to interact with a key cylinder or an electronic actuating mechanism. This latch assembly acts as a simple latch whose release mechanism is only operated manually via the interior or exterior door handles and attached rods/cables.
Part number 72150-SP0-A02 is described as a “Lock Assy., L. FR. Power Door.” It is made of steel, plastic, brass and rubber. Its main components are a latch body, outer door handle connecting rod, key cylinder rod, inside lock knob rod, switches, an electronic actuating mechanism and wiring harnesses. This lock assembly is used on the left front door of a vehicle that employs a central electronic door locking system.
You propose that part numbers 72110-SK7-A02 and 72150-SP0-A02 are classified as parts and accessories of motor vehicles in subheading 8708.29.5060, Harmonized Tariff Schedule of the United States (HTSUS). However, the exclusionary note in Note 2(b), Section XVII, which includes Chapter 87, provides that if the articles are classifiable as parts of general use of base metal, classification as a part or accessory in heading 8708 is precluded. "Parts of general use" are defined in Note 2, Section XV, HTSUS, as including, among other things, base metal articles of heading 8301, HTSUS. Heading 8301 includes, among other things, base metal locks of a kind used on motor vehicles and parts of locks. In addition, the general ENs to Section XV provide that in general, identifiable parts of articles are classified as such parts in their appropriate headings in the Nomenclature, however, parts of general use presented separately are not considered as parts of articles, but are classified in the headings of this Section appropriate to them. Since part numbers 72110-SK7-A02 and 72150-SP0-A02 include controlling mechanisms designed to function by operation of a key cylinder and/or electronic actuating mechanism, they are classified as locks/parts of locks in heading 8301, HTSUS.
The applicable subheading for part number 72110-SK7-A02 (Lock Assy., R. FR. Power Door) will be 8301.60.0000, HTSUS, which provides for padlocks and locks (key, combination or electrically operated), of base metal…other locks, parts. The rate of duty will be 2.8 percent ad valorem.
The applicable subheading for part number 76410-SA2-003 (Lock Assy., R. RR. Door) will be 8302.30.3060, HTSUS, which provides for base metal mountings, fittings and similar articles, other mountings, fittings and similar articles suitable for motor vehicles; and parts thereof, of iron or steel, of aluminum or of zinc, other. The rate of duty will be 2 percent ad valorem.
The applicable subheading for part number 72150-SP0-A02 (Lock Assy., L. FR. Power Door) will be 8301.20.0060, HTSUS, which provides for padlocks and locks(key, combination or electrically operated) of base metal... locks of a kind used on motor vehicles, other The rate of duty will be 5.7 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/.
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 Barbara Kaiser at (646) 733-3024.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division