CLA-2-87:OT:RR:NC:N2:206
Tim Parsons
Parsons Trading
1244 River Park Blvd. Napa, CA 94559
RE: The tariff classification of a steering wheel cover
Dear Mr. Parsons:
In your letter dated May 31, 2024, you requested a tariff classification and country of origin determination ruling on a Steering Wheel Cover, on behalf of your client, Duluth Trading. A sample was provided to this office with your request.
The item under consideration is a Steering Wheel Cover (Item Number 49704), which is designed to slide over a passenger vehicle steering wheel. You state that it measures 14.5 inches in outer diameter and is 1.5 inches thick with a slot along the inner diameter edge with sewn edges. It is made of a woven polyester outer surface with a rubber inside surface.
The applicable subheading for the Steering Wheel Cover (Item Number 49704) will be 8708.99.8180, Harmonized Tariff Schedule of the United States (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.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8708.99.8180, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8708.99.8180, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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/.
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.
With regard to the country of origin for the subject steering wheel cover, this office was unable to make a determination due to the lack of information. If you would like this office to issue a ruling on the country of origin of the steering wheel cover, please submit the information described below:
Please provide pictures of the raw materials imported from China to Cambodia. Provide pictorial diagrams of the manufacturing steps in Cambodia.
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