CLA-2-87:RR:NC:MM:101 G82495
Ms. Brenda K. Osborne
Manager, Customs Compliance
Mitsubishi Motor Sales of America, Inc.
6400 Katella Avenue
Cypress, California 90630-5208
RE: The tariff classification of motor vehicle manual transmission system parts:
Hub & Sleeve; Ring, Manual Transmission Synchronizer; Key, Manual Transmission Synchronizer; Spring, Manual Transmission; and Snap Ring from Japan
Dear Ms. Osborne:
In your letter dated September 19, 2000 you requested a tariff classification ruling.
You submitted samples and a diagram of the following motor vehicle manual transmission system parts:
Part # MD749414 - Hub & Sleeve
Part # MD734841 - Ring, Manual Transmission Synchronizer
Part # MD748663 - Key, Manual Transmission Synchronizer
Part # MD742445 - Spring, Manual Transmission
Part # MD703780 - Snap Ring
You state that the Hub & Sleeve is a one-piece unit consisting of a gear, a hub, and a sleeve. The Hub & Sleeve ride in the transaxle and are used to transmit power from one gear to the next. The Synchronizer Ring fits inside each side of the sleeve and is used to make the gears rotate at the same speed in order to prevent clash when the gears are about to mesh. The Synchronizer Key (also called an insert) is inserted into the groove cut part way into the Ring and the Hub & Sleeve. This Key prevents slippage between the two parts as they rotate together. The Spring is a retaining ring and is used to retain the Synchronizer Key's position. The Snap Ring is snapped into a groove in the shaft and is used to hold the gears in place.
You also state that the Hub & Sleeve, Ring, Key, and Spring are all parts that are specific only to automobile transmissions. They are not parts of general use. With regards to the Snap ring, while this part number and size is specific to this particular transmission, snap rings in general are often considered to be parts of general use.
The applicable subheading for the Spring, Manual Transmission will be 7318.24.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: Non-threaded articles: Cotters and cotter pins. The rate of duty will be 3.8% ad valorem.
The applicable subheading for the Hub & Sleeve; Ring, Manual Transmission Synchronizer; Key, Manual Transmission Synchronizer; and Snap Ring will be 8708.99.6700, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other parts for power trains. The rate of duty will be 2.5% ad valorem.
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 Robert DeSoucey at 212-637-7035.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division