CLA-2-84:OT:RR:NC:N1:104

Ms. Patricia Sanders Duffy
P.S. Customs Brokerage, Inc.
829 Fairways Court
Suite 110
Stockbridge, GA 30281

RE: The tariff classification of a Door Seal Application System from Germany

Dear Ms. Duffy:

In your letter dated August 26, 2015, on behalf of your client ThyssenKrupp System Engineering, you requested a tariff classification ruling.

The importation consists of an assembly line that installs seals to front doors and rear doors on automobiles. Installation involves a gluing/adhesion process. The line will be imported in one shipment and assembled at the importer’s site. The functional unit consists of two rotary tables with holding plates for the fixation of the spherical suspension which contains the lifting unit and the application plates for the “front door and/or the rear door”. The spherical suspension keeps the application plates in required basic position. Angular tolerances along with tolerances in x-, y- and z- direction are compensated through springs in the unit and the spherical connection with the application plates. An operator using the lifting unit can move the application plate into the correct position when loading the seals. A worker inserts the seal in the application plate manually by fixing it on the special seal support strips. The pressing of the seal on the door is done by pneumatic cylinders which are fixed on the application plate. No additional heat is applied. When the sealing process is complete, a tackle system receives the signal and the tackle with the door and the applied seal moves out of the station and the next tackle with a door comes in to start the process all over again. The tackle system is a separate system supplied by the importer. In accordance with Note 4 to Section XVI, the applicable subheading for the Door Seal Application System, as described above, will be 8479.89.9899, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter, parts thereof: Other machines and mechanical appliances: Other: Other: Other”. The rate of duty will be 2.5% 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 Patricia O’Donnell at [email protected].

Sincerely,

Gwenn Klein Kirschner
Director
National Commodity Specialist Division