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NY J82832

April 25, 2003

CLA-2-85:RR:NC:1:112 J82832


TARIFF NO.: 8543.89.9695

Dr. Henry Lyden
46 Cliff Road
Wellesley, MA 02481

RE: The tariff classification of a keyless entry system from Germany

Dear Dr. Lyden:

In your letter dated March 21, 2003 you requested a tariff classification ruling.

As indicated by the submitted descriptive literature, the keyless entry system is for use in an automobile and consists of a plastic housing that contains a microphone, an LED, a button, various electronics, and electrical wiring. This device is intended to operate as a type of keyless entry and is mounted within the vehicle. A programmed code is stored by the user and is activated by tapping on the window of the vehicle in a sequence that matches the stored code. An electrical signal is then generated and sent through the wiring to the vehicle’s electrical system, which, in turn, activates the switches that control the door locks.

The applicable subheading for the keyless entry system will be 8543.89.9695, Harmonized Tariff Schedule of the United States (HTS), which provides for other electrical machines and apparatus, , not specified or included elsewhere in Chapter 85, HTS. The rate of duty will be 2.6 percent ad valorem. This device, in and of itself, does not switch an electrical circuit and, accordingly, is excluded from classification under subheading 8536.50.9065, HTS.

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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