CLA-2-90:RR:NC:N1:105 R00489

Mr. Dennis Forhart
PricewaterhouseCoopers, LLP
400 Renaissance Center
Detroit, MI 48243

RE: The tariff classification of an Instrument Cluster Assembly from Mexico

Dear Mr. Forhart:

In your letter dated April 4, 2004, electronically transmitted to us June 23, 2004, for Freightliner LLC, you requested a tariff classification ruling. No samples were submitted.

You state: “Part number A22-48873-005, is a complete instrument cluster assembly that includes the housing, populated printed circuit board, lens, tachometer, the speedometer, air (pressure) gauges, oil and water temperature gauges, fuel gauge and transmission gauge.” The drawing you included is quite blurry, but we believe that it shows the tachometer and speedometer of equal sizes, but much larger than the other 6 dials.

You believe that the speedometer provides the essential character to the instrument cluster. We do not agree, but we do consider the items of HTS 9029 heading, the speedometer and the tachometer, to do so. Your item appears to be quite similar to the one that will contain the parts in Headquarters Ruling Letter 962895 JAS, 1-3-00.

The applicable subheading for your item will be 9029.20.4080, Harmonized Tariff Schedule of the United States (HTS), which provides for “other” speedometers and tachometers. The rate of duty will be free.

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 J. Sheridan at 646-733-3012.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division