CLA-2-87:OT:RR:NC:N2:206
Mr. Robert Leo
Meeks, Sheppard, Leo & Pillsbury LLP
570 Lexington Avenue
Suite 2405 New York, NY 10022
RE: The tariff classification of canvas motorhome doors from Turkey
Dear Mr. Leo:
In your letter dated November 6, 2023, you requested a tariff classification ruling on behalf of your client, Auto-Motion Shade, Inc.
The items under review are canvas motorhome doors for Class B recreational vehicles (RV), such as Mercedes Sprinter, Dodge Ram, and Ford Transit, which will be imported from Turkey through Canada.
The canvas motorhome doors are made from 100% heavy duty polyester. They are imported complete and ready to use. No further operations are performed in the U.S. other than attaching them to the specific RV motorhomes. A double-sided Velcro tape is glued to the vehicle and serves as the attachment method. In some cases, Auto-Motion Shade puts grommets into the fabric to use Velcro and drill hold-down screws to attach the canvas door to the vehicle. The doors act as barriers to wind, rain, or mosquitos, while allowing the user to let in air and light.
In your letter, you suggest that the canvas motorhome doors may be classified in heading 8708.29.1500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of motor vehicles of heading 8701 to 8705: Other parts and accessories of bodies (including cabs): Other: Door assemblies.” This office disagrees. The motorhome doors under consideration are not intended to be used as the main vehicle doors. They are an optional feature of the RV and do not replace or act as doors. The canvas motorhome doors are used for the comfort and protection of the passengers when the vehicle is parked and the main doors are open.
The applicable subheading for the canvas motorhome doors will be 8708.99.8180, HTSUS, which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: 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 at https://hts.usitc.gov/current.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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