CLA-2-90:RR:NC:N1:105 H88726
Mr. Neil R.Trenchard
Siemens Shared Services, LLC
Import-Export Services
186 Wood Avenue South
Iselin, NJ 08830
RE: The tariff classification of a PCB for an instrument panel from Germany
Dear Mr. Trenchard:
In your letter dated February 18, 2002, modified by your undated letter, plus attachment, faxed to NIS DeSoucey on February 25, you requested a tariff classification ruling. No samples were submitted.
The import VDO instrument cluster circuit board, part 992 700 686, has multiple integrated circuits, resistors, diodes, etc. It is a sub-assembly that will be used in the dashboard instrument cluster of an automobile. It receives electrical inputs from the Engine Control Unit, which has received raw electrical measurement data from various sensors in the car and has interpreted much of that data. For example, the ECU receives pulses from the transmission for each rotation and then from its internal clock and pre-programmed information about the relationship between those rotations and vehicle speed sends a simple electrical signal indicating speed to the import. The import performs some additional interpretation and routing into specific instructions for the odometer, speedometer, tachometer, fuel and temperature gauges, warning lamps, etc. The import has the electrical outputs which will power the sockets for the warning lights and the galvanometers that will turn the spindles of the gauges. However, as we understand your diagram and statements, the import “PCB” does not have the galvanometers, spindles, pointers, face plates, sockets or bulbs needed for the driver to directly perceive the information.
The import, per se, does not appear to be covered by any of the headings referred to in Note 2-a the Chapter 90. Per HRL 962895 JAS, dated 1/3/2000, this element of a subassembly of an automobile instrument cluster which perform functions relating to the eventual display of measurements and warnings relating to several different HTS headings is classified as a part of a speedometer/tachometer, not as a part of motor vehicle electrical signaling apparatus of HTS 8512.
Therefore, we agree that the applicable subheading for this import will be 9029.90.8040, Harmonized Tariff Schedule of the United States (HTS), which provides for parts and accessories of 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