CLA-2-87:OT:RR:NC:N2:206
Alex Krason
Analyst
Nissan North America
One Nissan Way
Franklin, TN 37067
RE: The tariff classification of motor vehicle components from Japan.
Dear Mr. Krason:
In your letter dated July 27, 2020, you requested a tariff classification ruling. Pictures and other descriptive literature were submitted with your request.
The items under review have been identified as a Map Lamp Console Assembly (Part Number 264303TA9A), a Key Cylinder Barrel (Part Number 806013TS0A), an Engine Fuel Rail/Tube Assembly Fuel (Part Number 175216LB0A), and an Engine Mount (Part Number 112546FM0A).
The first item is the Map Lamp Console Assembly, which is installed onto the interior roof of the vehicle. The assembly part is incorporated with a sunglass storage console, a map lamp unit, a microphone, and interior light switches, where the console covers a larger portion of the assembly. The map lamp unit provides lighting to the interior area of the vehicle, which can be turned on/off with the light switches provided in the assembly itself.
In your letter, you discuss a possible classification of the Map Lamp Console Assembly in headings 8708, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of vehicles; 8512, HTSUS, which provides for electrical lighting and signaling equipment; 8518, HTSUS, which provides for microphones; and 8536, which provides for electrical switches.
Tariff classification under the HTSUS is governed by the principles set forth in the General Rules of Interpretation (GRIs). GRI 3(b) is applicable when goods are, prima facie, classifiable under two or more headings, and are composite goods, such as the map lamp assembly. GRI 3(b) states that the goods “shall be classified as if they consisted of the material or component which gives them their essential character.” The essential character of the map lamp console assembly is its lighting feature. The microphone, sunglass case, and switches are secondary to the assembly.
The applicable subheading for the Map Lamp Console Assembly (Part Number 264303TA9A) will be 8512.20.2040, which provides for “Electrical lighting or signaling equipment (excluding articles of heading 8539), windshield wipers, defrosters and demisters, of a kind used for cycles or motor vehicles; parts thereof: Other lighting or visual signaling equipment: Lighting equipment: For the vehicles of subheading 8701.20 or heading 8702, 8703, 8704, 8705 or 8711”. The general rate of duty will be Free.
Item number two in your request is described as a key cylinder barrel, which is a vehicle door lock mechanism. The mechanism is comprised of a cylinder assembly, E-clip, cover case, retainer spring, holder rod, lever, and case. When locked, the cylinder engages a series of spring loaded pins which prevents the cylinder from turning. When the correct key is inserted, the uneven edges of the key push the pins upward which opens the cylinder, unlocking the door.
The applicable subheading for the Key Cylinder Barrel (Part Number 806013TS0A), will be 8301.20.0060, HTSUS, which provides for “Padlocks and locks (key, combination or electrically operated) of base metal clasps and frames with clasps, incorporating locks, of base metal; keys and parts of any of the foregoing articles of base metal: Locks of a kind used on motor vehicles… Other.” The rate of duty will be 5.7 percent ad valorem.
Item number three is a fuel rail/tube assembly fuel, which is installed onto the vehicle’s engine. A fuel rail is high pressure tubing which takes pressurized fuel from a high pressure pump to the injectors in an internal combustion engine. You state that in a common rail direct injection system, the fuel rail constantly stores and supplies the fuel to the solenoid valve injectors at the required pressure. This pressure then remains permanently available throughout the fuel line. The fuel rail is bolted to the engine cylinder head.
Consideration was given to classifying the fuel rail in heading 8409, HTSUS, as parts of automotive engines, as you suggested. However, fuel rails are external components of the engine. Although they are connected to it, the engine is complete without the fuel rails and is not normally sold with the fuel rails attached to it. In HQ H259645, dated June 15, 2026, CBP discussed the classification of similar fuel rails. In this ruling, it states that, “The purpose of the fuel rails and fuel rails with integrated fuel injectors is to deliver gasoline from the fuel tank to the combustion chamber in a motor vehicle engine.” As a result, the tube assembly fuel is not a part of engines, and classification of the fuel rail in heading 8409, HTSUS, is precluded.
The applicable subheading for the Engine Fuel Rail/Tube Assembly Fuel (Part Number 175216LB0A) will be 8708.99.8180, which provides for “Parts and accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other.” The general rate of duty will be 2.5 percent ad valorem.
Item number four in your request is described as an engine mount, which is a vehicle engine support mount. The mount is made of aluminum alloy. You state this article is used to mount the engine to the side frame of the vehicle by means of bolts in the engine compartment.
You suggest classification for the engine support mount in heading 8708, HTSUS, which provides for which provides for parts of vehicles. However, the exclusionary note in Note 2(b), Section XVII, which includes Chapter 87, provides that if the article is classifiable as a “part 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 8302, HTSUS. Heading 8302 includes, in pertinent part, base metal mountings, fittings and similar articles suitable for coachwork.
In addition, the Explanatory Notes (EN) 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 the Section appropriate to them. We find that the subject engine support mount, which serves a mounting function for the vehicle’s engine, is classified in heading 8302, HTSUS. As such, the engine support mount is considered “parts of general use” per Note 2(c) to Section XV and is precluded from classification in heading 8708, HTSUS.
The applicable subheading for the Engine Mount (Part No: 112546FM0A) will be 8302.30.3060, HTSUS, which provides for “Base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork…: 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.
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