CLA-2-87:OT:RR:NC:N2:206

Lora Mayo-Brown
Import Supervisor, International Trade
Robert Bosch LLC
8101 Dorchester Road
North Charleston, SC 29418

RE: The tariff classification of a CVT Pushbelt from the Netherlands

Dear Ms. Mayo-Brown:

In your letter dated February 5, 2020, you requested a tariff classification ruling. A sample was provided with your request, which is being returned to you.

The item under consideration has been identified as a Continuously Variable Transmission Pushbelt (CVT Pushbelt), which is used in automotive applications. You state that the CVT Pushbelt is a core element of a continuously variable transmission, which transmits the engine output to the drive axle. The CVT Pushbelt is made up of individual carbon steel elements that are stringed together along two high-alloy steel ring packs. The transmission ratio is continuously variable as the CVT Pushbelt rotates between two pulleys consisting of two conical sheaves located on the input and output shaft. These pairs of conical sheaves adjust the running radius of the CVT Pushbelt according to speed and torque.

You suggested classifying the CVT Pushbelt in heading 8708, Harmonized Tariff Schedule of the United States (HTSUS), as parts of automotive gearboxes (transmissions). As an alternate classification for this product, you suggested classification under heading 7326, HTSUS, which provides for other articles of iron or steel.  Heading 7326 covers a wide range of iron or steel articles that are not more specifically provided for elsewhere in the HTSUS.  Noting that the CVT Pushbelt under consideration is more specifically provided for as parts of transmissions in heading 8708, HTSUS, the subject CVT Pushbelt would be excluded from heading 7326 (and therefore subheading 7326.90.8688), HTSUS.

The applicable subheading for the CVT Pushbelt will be 8708.40.7580, HTSUS, which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Gear boxes and parts thereof: Parts: 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 https://hts.usitc.gov/current.

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, please contact National Import Specialist Liana Alvarez at [email protected].


Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division