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HQ 962895

JANUARY 3, 2000

CLA-2 RR:CR:GC 962895 JAS


TARIFF NO.: 9029.90.80

Timothy Shepherd
Nissin Customs Service, Inc.
101 Mark Street, Suite G
Wood Dale, IL 60191

RE: NY D81206 Revoked; Components for Instrument Clusters for Automobiles and Motorcycles

Dear Mr. Shepherd:

This is in reference to NY D81206, which the Director of Customs National Commodity Specialist Division, New York, issued to Nissin Customs Service on August 27, 1998. This ruling concerned the classification under the Harmonized Tariff Schedule of the United States (HTSUS), of components for instrument clusters for automobiles and motorcycles.

Pursuant to section 625(c), Tariff Act of 1930 (19 U.S.C. 1625(c)), as amended by section 623 of Title VI (Customs Modernization) of the North American Free Trade Agreement Implementation Act, Pub. L. 103-182, 107 Stat. 2057, 2186 (1993), notice of the proposed revocation of NY D81206 was published on November 24, 1999, in the Customs Bulletin, Volume 33, Number 47. No comments were received in response to that notice.


In NY D81206 articles identified as a meter hood, case, and cover for instrument clusters used in motor cycles and automobiles were held to be classifiable in subheading 8708.29.50, HTSUS, as parts and accessories of motor vehicle bodies. A review of the schematic drawing submitted with the original ruling request, together with information contained in your May 23 letter, and additional information you provided by telephone on October 1, 1999, indicates the following.

Instrument clusters consist of multiple independent components and display units, all in the same housing. They come in various configurations. The one of which these three articles are components has a fuel/water gauge on the right, a tachometer module on the left, and a speedometer module in the middle, beneath which is an LCD odometer gauge. The meter hood assembly, identified in NY D81206 as the meter hood, consists of a plastic lens, item 1 on the schematic, together with the visor meter assembly, item 3 on the schematic, and an illumination control knob, item 6 on the schematic. The meter hood assembly, together with the case and cover, both of plastic and identified as items 7 and 10, respectively, in the ruling and the schematic, are in issue here.

A printed circuit board snaps into one end of the case and the combined fuel/water gauge, tachometer and speedometer/ odometer module snaps into the other end. The plastic case acts as a housing for both components. The meter hood assembly fits onto the top of this configuration more or less as a combination dust cover/lens and the plastic cover fits onto the bottom to complete the instrument cluster. The cluster is screwed to the vehicle body through holes in the cover. When the engine is turned on, a program of calculations or memory, most likely from a CD-ROM located off-board, is downloaded onto the printed circuit board in the instrument cluster. An engine control unit (ECU) mounted in the engine compartment receives electrical impulses from sensors on various automotive components to analyze engine performance. The ECU decodes and converts these impulses into output signals which it sends to the printed circuit board. The board=s memory utilizes these signals to compute the data which is displayed as readouts on the fuel/water gauge and the tachometer and speedometer/odometer module.

You cite a ruling, NY 873948, in which a substantially similar instrument cluster was held to be classified as other speedometers and tachometers, in subheading 9029.20.40, HTSUS. You conclude that under Chapter 90, Note 2(b), HTSUS, the articles in issue here, the meter hood assembly, case and cover, are parts suitable for use solely or principally with the apparatus of heading 9029.

The HTSUS provisions under consideration are as follows:

8708 Parts and accessories of the motor vehicles of headings 8701 to 8705:

Other parts and accessories of bodies (Including cabs)

8708.29 Other:

8708.29.50 Other

9029 ...odometers...and the like; speedometers and tachometers, other than those of heading 9014 or 9015...; parts and accessories thereof:

9029.20 Speedometers and tachometers;...:

9029.90 Parts and accessories:

9029.90.80 Other


Whether the meter hood, the case and the cover are parts and accessories of apparatus of heading 9029.


Under General Rule of Interpretation (GRI) 1, Harmonized Tariff Schedule of the United States (HTSUS), goods are to be classified according to the terms of the headings and any relative section or chapter notes, and provided the headings or notes do not require otherwise, according to GRIs 2 through 6.

Under Section XVII, Note 2(g), HTSUS, the expressions Aparts@ and Aparts and accessories@ do not apply to articles of Chapter 90. Goods that are identifiable as parts and accessories of machines, instruments or apparatus of Chapter 90 are to be classified in accordance with Chapter 90, Note 2, HTSUS. See HQ 954662, dated December 7, 1994, and related cases. Parts and accessories which are goods included in a heading of chapter 90, or of chapter 84, 85 or 91, are in all cases to be classified in their respective headings. See Note 2(a). Other parts and
accessories suitable for use solely or principally with a number of machines, instruments or apparatus of the same heading are to be classified with those machines, instruments or apparatus. See Note 2(b). In NY 873948, dated May 14, 1992, instrument clusters for motorcycles and automobiles, each consisting of a speedometer and tachometer, together with fuel gauge, oil pressure gauge, a voltmeter and temperature gauge, all in a common housing, were held to be classifiable in subheading 9029.20.40, HTSUS. The ruling noted that the combined value of the speedometer and tachometer in each cluster was 70 percent or higher depending on the number of gauges in the cluster. Some of the components in the instrument clusters the subject of NY 873948 were classified in headings of Chapter 90 other than 9029, thus requiring application of GRI 3, HTSUS. HQ 958997, dated October 31, 1996, clarified NY 873948 by stating that heading 9029 was not broad enough in scope to include components classified in other headings, and that the proper basis for the decision in NY 873948 was as a composite good in which, under GRI 3(b), the speedometer imparted the essential character to the whole.

In this case, it is apparent that the printed circuit board and fuel/water gauge, tachometer and speedometer/odometer module, when assembled with the meter hood assembly, case, and cover, constitute apparatus which is classifiable as speedometers, in subheading 9029.20.40, in accordance with NY 873948 and HQ 958997.


The meter hood, case, and cover, the subject of NY D81206, are integral, constituent components necessary to the completion and proper function of speedometers. As parts suitable for use solely or principally with this instrument, they are classifiable in subheading 9029.90.80, HTSUS, under the authority of Chapter 90, Note 2(b).


NY D81206, dated August 27, 1998, is revoked. In accordance with 19 U.S.C. 1625(c), this ruling will become effective 60 days after its publication in the Customs Bulletin.


John Durant, Director
Commercial Rulings Division

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