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 front and rear knuckles from Japan.
Dear Mr. Krason:
In your letter dated October 8, 2020, you requested a tariff classification ruling. Pictures and other descriptive literature were submitted with your request.
The items under consideration have been identified as a Front Knuckle (400145RY0A - KNU-STRG, RH), and a Rear Knuckle (43018CK000 - HSG ASSY-RR AXLE, RH), used in passenger vehicles. The front knuckle is composed of 93.6 percent of cast iron and serves as the pivot point of the steering system, which allows the wheels to turn. It is connected to the steering system and the wheel by the suspension system. It has an opening to allow connection of the axle shaft to the wheel hub. The front knuckle connects the strut assembly and the lower control arm. The tie rod transfers the lateral motion of the power steering rack to the front knuckle in order to turn the vehicle wheels.
The rear knuckle is composed of 97.5 percent of cast iron and attaches to the various suspension arms. It functions in conjunction with other suspension components to suspend the vehicle’s drive train above the wheels and acts as a mounting base for the wheel hub bearing assembly, rear brake caliper assembly, and rear brake disc/drum.
Consideration was given to classifying the front knuckle in subheading 8708.94, Harmonized Tariff Schedule of the United States (HTSUS), as parts of steering systems, as you suggested. However, subheading 8708.94 only provides for steering wheels, steering columns, steering boxes, and parts thereof. The front knuckle does not fall under any of the listed articles or their parts. In addition, the Road & Track Illustrated Automotive Dictionary (Revised Edition, 2000) defines "suspension" as "the … linkages used to suspend a car's … drive train above its wheels". The primary function of a front knuckle is as a linkage, which aids in suspending a vehicle drive train above its wheels (and hub assembly), and the fact it also pivots to allow steering of the wheels is a secondary function dictated simply by its location.
The applicable subheading for the Front Knuckle (400145RY0A - KNU-STRG, RH), and the Rear Knuckle (43018CK000 - HSG ASSY-RR AXLE, RH) will be 8708.80.6000, HTSUS, which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Suspension system and parts thereof: Parts: Other: Of cast iron.” The general rate of duty will be Free.
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