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HQ 964210

FEBRUARY 20, 2001

CLA-2 RR:CR:GC 964210 JAS


TARIFF NO.: 8708.29.50

Mr. Robert J. Resetar
Porsche Cars North America, Inc.
980 Hammond Drive, Suite 1000
Atlanta, GA 30328

RE: Fuel Filler Covers; NY F86610 Clarified

Dear Mr. Resetar:

In your letter to the Director of Customs National Commodity Specialist Division, New York, dated May 10, 2000, you inquire as to the classification, under the Harmonized Tariff Schedule of the United States (HTSUS), of fuel filler covers. You submitted diagrams from your electronics parts catalog. Our New York office will return the samples as you have requested.


The articles under consideration are fuel filler covers, identified in the catalog as the filler inlet compartment lid, part 996 504 133 00, and the tank filler neck cover, part 644 504 031 00. Both are stamped, oval pieces of sheet metal measuring 7 in. x 5 in. x 1/2 in. and 8 1/4 in. x 4 3/4 in. respectively. The first cover has a spring hinge and closing catch welded on while the second cover has a backing plate attached to the face plate by an adhesive glue and the back of the face plate crimped over to form a lip. A hinge and closing catch are attached to the first cover at the time of assembly to the car. These covers attach to the right front fenders of the vehicle covering the fuel fill compartment and gas cap.

You maintain these covers are provided for in HTSUS subheading 8708.29.50 as parts and accessories of motor vehicle bodies. However, the question remains whether for statistical purposes they are body stampings or other parts and accessories of bodies.

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):


Other parts and accessories:

8708.99.80 Other


Whether the fuel filler covers are parts and accessories of motor vehicle bodies.


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.

Rulings are issued pursuant to Part 177 of the Customs Regulations (19 CFR Part 177) on the proper classification of goods under the HTSUS at the 8-digit tariff rate subheading level. We agree that subheading 8708.29.50 is a relatively more specific provision for the fuel filler covers than is subheading 8708.99.80. Issues concerning the appropriate statistical suffix are not ordinarily the subject of the rulings process. In this case, however, stamping is a general term covering almost all press operations, to include blanking. Blanks are generally pieces of sheet material produced in cutting dies, usually in unfinished condition, that require cutting, machining or some other operation to produce the final shape. See Metals Handbook, Vol. 1, pp. 4 and 36 (8th ed., 1961). The fuel filler covers are stamped oval pieces of sheet metal that have been further processed, as described, into discrete, identifiable articles of commerce. They can no longer be regarded as mere stampings for tariff purposes.

For clarification purposes, in NY F86610, issued to you on May 10, 2000, a bumper reinforcement, among other articles, was found to be classifiable in subheading 8708.10.6010, HTSUSA, as parts of bumpers, stampings. These articles, however, were described as stamped steel beams to which other support components were welded after the initial stamping. Consistent with the discussion above, the bumper reinforcement is not a “stamping” for tariff purposes. The correct classification is subheading 8708.10.6050, HTSUSA, parts of bumpers, other.


Under the authority of GRI 1, the fuel filler covers, parts 996 504 133 00 and 644 504 031 00, are provided for in heading 8708. They are classifiable in subheading 8708.29.5060, HTSUSA.

NY F86610, dated May 10, 2000, is clarified as indicated.


John Durant, Director
Commercial Rulings Division

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