CLA-2-90:RR:NC:MM:105 G88467
Mr. Ron Reuben
Danzas AEI Technical Services
5510 West 102nd Street
Los Angeles, CA 90045
RE: The tariff classification of an automatic tire pressure system from Argentina
Dear Mr. Reuben:
In your letter, dated March 12, 2001, for S.A.F.E.R., you requested a tariff classification ruling.
No sample was submitted, but from the literature submitted, the imported system includes pressure gauges for each wheel to measure the pressure of the air in that tire and to continuously report that information to the imported control panel. Per the Vigia three page flyer, the control panel for the three manometer version is about 7 by 3 by 6 inches in size. The control panel displays information about the pressure in the tires and, more importantly, uses that information to send instruction to valves from a source of pressurized air (which source is not part of the import) to add or reduce air to the tire. In this way the pressure entered by the driver for each kind of tire, e.g., steering, traction or trailer, will be maintained automatically in each tire at that level despite slow leaks, temperature changes, etc An alarm will sound in the unusual circumstance that the system is not able to maintain the tire pressure in the desired range (due to a blow-out, for example).
The system includes various filters, connectors, hoses, etc. You state, “The importer plans to ship one system per disposable carton.”
You propose classification in HTS 9032.89.6050. However, the item is more specifically described at the six digit level as a manostat. See Explanatory Note I-A (Pressure controllers) to Harmonized System Heading 9032.
You state, “We also request comment on the proper placement of Country-of-Origin markings.” You also state, “The importer feel the best location for the Country-of-Origin marking would be on the case of the Control Panel.”
Obviously, without a sample of the marked item, we cannot rule on that marking. From the description, it might well meet the “conspicuous” requirement in CR 134.11. We assume from your letter that Argentina is the country of origin of all the significant elements of the system.
The applicable subheading for this item will be 9032.20.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for Manostats. The general rate of duty will be 1.7 percent ad valorem.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
Per your request, the literature you sent is being returned to you, in a separate mailing.
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 James Sheridan at 212-637-7037.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division