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HQ 082793

August 10, 1989

CLA-2 CO:R:C:G 082793 VEA


TARIFF NO.: 8544.30.00.

William Joffrey
William F. Joffrey Custom House Brokers Inc. P.O. Box 698
Nogales, Arizona 85628-0698

RE: Wiring harnesses used in motor vehicle lighting equipment

Dear Mr. Joffrey:

Your inquiry dated July 5, 1988, on behalf of Coleman Products Co., requests reconsideration of a New York ruling dated June 21, 1988 (File # 830553), classifying electrical wiring harnesses in heading 8544.30.00 of the Harmonized Tariff Schedule of the United States (HTSUS).


The submission states that the wiring harness is imported from Mexico and is used in motor vehicle lighting equipment. The harness consists of twin insulated electrical wires fitted at one end with a twin lead connector and an electrical light socket with or without its light bulb at the other end. The New York office classified the merchandise under subheading 8544.30.0000, HTSUS.

You disagree with this classification claiming that the harnesses should be classified under subheading 8512.90.6000 because they are used exclusively in motor vehicle lighting equipment. The request for classification was submitted to the New York office for reconsideration and forwarded to Headquarters for resolution.


Whether wiring harnesses used in lighting systems for motor vehicles are insulated electrical conductors within the terms of heading 8544, or whether they are electric lightning equipment within the terms of heading 8512, HTSUS.


The General Rules of Interpretation (GRI's), the legal principles by which merchandise is classified, govern classification under the HTSUS. GRI 1 states, in part, that classification shall be determined according to the terms of the headings and any relative section or chapter notes. Under the HTSUS, electrical articles are classified in Chapter 85. The competing headings 8512 and 8544 provide:

8512 Electrical lighting or signaling equipment (excluding articles of heading 8539), windshield wipers, defrosters and demisters, of a kind used for cycles or motor vehicles; parts thereof:

8544 Insulated (including enameled or anodized) wire, cable (including coaxial cable) and other insulated electric conductors whether or not fitted with connectors; optical fiber cables, made up of individually sheathed fibers, whether or not assembled with electric conductors or fitted with connectors:

8544.30.00 Ignition wiring sets and other wiring sets of a kind used in vehicles, aircraft or ships.

The wiring harnesses are precluded from classification in heading 8512. The Explanatory Notes describe the articles intended for classification in that heading. They exclude insulated electric wire and cable, whether or not cut to length or fitted with connectors or made up in sets. These articles are provided for in heading 8544.

The Explanatory Notes to heading 8544 state that it covers electric wire, cable and other conductors (e.g. braids, strip bars) used as conductors in electrical machinery, apparatus or installations, provided that they are insulated. The insulated wires and cables covered in this heading include:

(1) single or multiple strand insulated wires twisted together, (2) two or more such insulated wires twisted together, and (3) two or more such insulated wires assembled together in a common insulating sheath. Fitting the wire or cable with connectors (e.g. plugs, sockets, lugs, jacks, sleeves or terminals) at one or both ends, or cutting it to length does not preclude classification under 8544. The wiring harnesses in this case clearly fall within this provision. They are comprised of two insulated wires fitted at one end with a twin lead connector and an electrical light socket.

It is our position that the harness, if imported with its light bulb attached would also be classified under heading 8455 as a composite good whose essential character is determined by the wiring harness under GRI 3(b). GRI 3(b) states that mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale, which cannot be classified by reference to 3(a), shall be classified as if they consisted of the material or component which gives them their essential character.


Wiring harnesses used in lighting systems for motor vehicles are properly classifiable in heading 8544, subheading 8544.30.00 as insulated electric conductors.


John Durant, Director

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