CLA-2-83:OT:RR:NC:N1:121

Mr. Robert Scott
Williams Controls, Inc.
14100 SW 72nd Avenue
Portland, OR 97224

RE: The tariff classification of a plate insert

Dear Mr. Scott:

In your letter dated November 3, 2009, you requested a tariff classification ruling on a plate insert made in the United States.

The merchandise is described as a plate insert (item number 134081) that is used primarily in motor homes, buses and medium and heavy duty trucks. It is a steel plate on which the throttle and the brake components of a dual pedal system will be mounted and then fastened to the vehicle firewall. While the throttle pedal is simply mounted to the plate, the brake pedal is assembled through the plate by an adapter that connects it to a brake valve. In your letter, you suggest classification of the insert plate under tariff number 8708.99.8180, which provides for parts of motor vehicles. However, the National Import Specialist who handles car parts states that the insert plate is a not a part or an accessory.

The applicable subheading for the plate insert will be 8302.30.30, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other mountings, fittings and similar articles suitable for motor vehicles, and parts thereof, of iron or steel, of aluminum or of zinc.

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