CLA-2-85:OT:RR:NC:N4:112
James MacNeill
MacNeill Consulting Services
P.O. Box 1214
Bristol, CT 06011
RE: The tariff classification of an electronic control module (ECU) from Germany
Dear Mr. MacNeil:
In your letter dated October 29, 2015, you requested a tariff classification ruling.
The item concerned is an electronic control module (ECU) which is used in conjunction with the anti-lock braking system (ABS) of a vehicle. The ABS ECU is an encased electronic control module which would be connected by wiring to the main electronics system of a vehicle. It is used to process sensor input data and regulate the braking system to prevent brake lockup and slippage.
The ABS ECU receives input signals from a variety of sensors throughout the vehicle, including speed sensors placed at all wheel locations, brake pressure sensors, roll stability sensors, and steering angle sensors. The ABS ECU also receives engine speed input signals from an engine ECU (Motor Control Module), and ensures that the ABS valve is functioning properly. If the ABS ECU determines that corrections need to be made, it would issue several output signals which would be used to control and moderate the performance of the vehicle. If the vehicle is using cruise control, it would shut the cruise control off and can also send warning signals to the dashboard. To prevent brake locking and slipping, the ABS ECU controls the ABS valve by sending a pulsing electrical signal to the valve, thus alternatingly activating and deactivating the valve to prevent wheel lock. The ABS ECU incorporates four multi-pin connectors, necessary for placing it into an electrical system, but does not contain any electrical switching or protection apparatus.
The applicable subheading for the electronic control module (ABS ECU) will be 8543.70.9650, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Other machines and apparatus: Other: Other: Other: Other.” The rate of duty will be 2.6.
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 Steven Pollichino at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division