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NY I88173

November 19, 2002

CLA-2-85:RR:NC:1:112 I88173


TARIFF NO.: 8536.69.8000; 8537.10.9070; 8543.89.9695

Mr. Alberto A. Pedraza
Pedraza Customhouse Brokers, Inc.
P.O. Box 450057
Laredo, TX 78405

RE: The tariff classification of automotive electrical devices; the country of origin is not stated.

Dear Mr. Pedraza:

In your letter dated October 31, 2002, on behalf of Kostal Mexicana, S.A., you requested a tariff classification ruling.

As indicated by the submitted descriptive literature, there are five items in question, identified as a roll connector (rotary coupler), a memory seat module, a steering angle sensor, a rain sensor, and a steering column module electronic unit. The roll connector (rotary coupler) is a housing that incorporates an electrical connector and a device known as a “clockspring”. It is assembled into the steering column of an automobile. The connector is designed to accept a wiring harness or other electrical wiring, while the “clockspring” is a circular device that allows the steering wheel to turn freely without damage to the electrical wiring. The memory seat module is an electronic device that controls the position of the seats, mirrors and steering column. The steering angle sensor works as a type of encoder to sense the position of the steering wheel as it interacts with the roll connector (rotary coupler). The steering column module electronic unit consists of a circuit board with various electronic devices and serves to receive information from other components and translate that information into network messages.

The applicable subheading for the roll connector (rotary coupler) will be 8536.69.8000, Harmonized Tariff Schedule of the United States (HTS), which provides for other apparatus for making connections to or in electrical circuits. The general rate of duty will be 2.7 percent ad valorem. The applicable subheading for the memory seat module will be 8537.10.9070, HTS, which provides for other boards, panels, , and other bases, , for electric control or the distribution of electricity, : For a voltage not exceeding 1,000 V. The general rate of duty will be 2.7 percent ad valorem. The applicable subheading for the steering angle sensor and the steering column module electronic unit will be 8543.89.9695, HTS, which provides for other electrical machines and apparatus, , not specified or included elsewhere in Chapter 85, HTS. The general rate of duty will be 2.6 percent ad valorem.

Your inquiry does not provide enough information for us to give a classification ruling on the rain sensor. Your request for a classification ruling should include a breakdown of the components that comprise the rain sensor. In addition, please explain exactly how these components interact to perform the sensor’s function. When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.

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 David Curran at 646-733-3017.


Robert B. Swierupski

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