CLA-2-87:OT:RR:NC:N2:201
Susan Ampudia, US Customs Broker
International Trade & Customs Specialists, Inc.
13703 N. Lamar Dr
Laredo, Texas 78045
RE: The tariff classification of motor vehicle headlamps from Mexico
Dear Ms. Ampudia:
In your letter dated May 4, 2021, you requested a tariff classification ruling on behalf of your client ZKW Mexico, SA de CV (“ZKW”).
You state that your customer, ZKW, is a manufacturer of automotive headlamps and plans to import Mercedes Benz headlamps into the United States. At present, ZKW only is requesting classification of two (2) different models of headlamps and one (1) dummy auxiliary headlamp.
The first item under consideration has been identified as Model 1251, which will be imported in a High, Low, and Auxiliary version headlamp. Its main function is to increase the visibility on the road and increase awareness for vehicle driving. The light source is a “Module LED” that has light functions. The headlamp has a turn indicator, low beam, daytime run light, high beam, cornering, and pixel segment.
The second item under consideration has been identified as Model 1250, which will be imported in a High, Low, and Auxiliary version headlamp. Its main function is to increase the visibility on the road and increase awareness for vehicle driving. The light source is a “Reflector LED” that has light functions. The headlamp has a turn indicator, low beam, daytime run light and high beam.
The third item under consideration has been identified as an Auxiliary Headlamp (Dummy) in both the 1251 and 1250 models and is non-functional. Its main function is to increase awareness for vehicle driving. There is no light source, and it does not function as a headlamp.
In your request, you suggest that the articles submitted should be appropriately classified in 8512.20.2040, Harmonized Tariff Schedule of the United States (HTSUS). We agree for models 1251 and 1250. However, the Auxiliary Headlamp (Dummy) is not equipped with any light source, nor is it designed to accept one, therefore it cannot be classified as either an electrical lighting or signaling device.
The applicable subheading for headlamps models 1251 (High, Low, Functional Auxiliary) and 1250 (High, Low, Functional Auxiliary), will be 8512.20.2040, HTSUS, 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: For the vehicles…”. The duty rate will be Free.
The applicable subheading for the Auxiliary Headlamp (Dummy) will be 9002.90.9500, HTSUS, which provides for “Lenses, prisms, mirrors and other optical elements, of any material, mounted, being parts of or fittings for instruments or apparatus, other than such elements of glass not optically worked; parts and accessories thereof: Other: Other: Other.” 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 the 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, contact National Import Specialist Matthew Sullivan at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division