CLA-2-84:RR:NC:1:102 F80523
Mr. Ralph Sheppard
Meeks & Sheppard
1735 Post Road (Suite 4)
Fairfield, Connecticut 06430
RE: The tariff classification of flow control parts for automotive HVAC systems.
Dear Mr. Sheppard:
In your letter dated December 2, 1999 you requested a tariff classification ruling on behalf of your client DENSO Manufacturing.
The articles in question are identified as part numbers 116660-1230, intake damper door, 116621-8110, intake damper lever, 116681-8090, intake damper lever, 116660-1281, driver air mix damper door, and 116680-8270, driver air mix damper lever. Samples were submitted.
The damper doors and damper actuating levers are described as components used in the manufacture of automotive heating, ventilation and cooling (HVAC) systems. These systems are typically comprised of a blower, heater and air conditioning coil, with thermal exchange elements encased in a plastic housing together with foam-covered damper doors and the damper actuating levers, plates and other parts necessary for the functioning of the HVAC system. The plastic housing is in multiple pieces that are attached to each other after the dampers and thermal exchange elements are assembled within the housings.
The damper doors, when assembled in their housing, form an appliance for controlling the flow of air from either the outside or from within the passenger compartment of the vehicle, through the various heat exchange elements of the HVAC system. The damper doors, together with the damper actuating levers, function as a closure mechanism within the appliance. The dampers may be actuated by mechanical cables or servomotors, depending on the design of the HVAC system, and are generally interconnected with other dampers, so that the movement of one damper door results in the movement of one or more related dampers. The actuating levers for the damper doors form the mechanical connection between the damper doors and the actuator that will be used to operate the closure mechanism, i.e., a servomotor or manual cable device.
The applicable subheading for the damper doors and the damper actuating levers will be 8481.90.9080, Harmonized Tariff Schedule of the United States (HTS), which provides for other parts of taps, cocks, valves and similar appliances. 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 Kenneth T. Brock at 212-637-7026.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division