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NY J83332

March 27, 2003

CLA-2-87:RR:NC:MM:101 J83332


TARIFF NO.: 8703

Mr. Carl D. Cammarata
Law Offices of George D. Tuttle, P.C.
Three Embarcadero Center, Suite 1160
San Francisco, California 94111

RE: The tariff classification of Leather Dedicated Containers and Holders for Porsche Carrera GT Automobiles from Italy

Dear Mr. Cammarata:

In your letter dated March 6, 2003 you requested a tariff classification ruling.

You submitted five samples of Leather Dedicated Containers and Holders for Porsche Carrera GT Automobiles. These items are manufactured in Italy. You state that these five leather items to be installed in the 2004 Porsche Carrera GT automobiles prior to importation are:

Console CD Holder
Door Side Pocket Holders
Seat Clothing holder
Trunk Compartment Storage Holder
Document Case

You state that these items are to be installed by the factory in Germany during the manufacturing process in the new limited production Porsche Carrera GT models in 2004. You state that these parts will not be offered for sale separately, as the only time they will be available is with the vehicle at the time of importation. They will not be imported separately for sale, nor will they be offered for sale without the vehicle. You state that as component parts (they come “standard” with the vehicle – they are not ordered), the price of these items will be included in the sales price of the Carrera GT model. They are for use exclusively with the new Carrera GT.

The Seat Clothing Holder – is a leather seat-back holder for clothing that may be needed while driving. The Holder is affixed to the rear of the passenger seat and is held in place by two embedded eyelets that attach to the specially designed and spaced hooks on the rear of the passenger seat. It fits exactly into the cavity behind the seat bordered by the center console, firewall, and the side of the vehicle. Although the Holder is removable, it is designed and intended to remain in the vehicle at all times.

The Door Side Pockets – are long, narrow, zippered leather door pockets with unique measurements to conform to the shape of the door cavity within which it is installed. Because of its unique shape, it will only fit into the Carrera GT door cavity, and is designed to conveniently hold small change, as well as other needed items (cigarettes, lighters, keys, glasses, etc.). The Pocket is designed to remain permanently within the vehicle.

The Document Holder – is a leather container designed to hold the vehicle’s important papers (Owners Manual, Warranty Papers, Insurance Papers, License, Registration, etc.). It fits on the floor of the vehicle behind the driver’s seat and has a handle for easy access. It is designed and intended to be kept in the vehicle at all times.

The Console CD Holder – is a specially designed and shaped leather container that conforms to the shape of the inside of the vehicle’s center console. It fits exactly into the space provided for it in the center console between the driver and the passenger seats, and is affixed to the console’s slide-out mechanism. Although it can be removed from the sliding mechanism for periodic loading or cleaning, it will remain a permanent part of the vehicle.

The Trunk Compartment Storage Holder - is a leather container designed to hold the cargo items together so as to prevent damage to both the stored items and the inside of the vehicle’s cargo compartment by keeping the cargo from sliding and to eliminate rattling. It is a hold-all liner that is a trapezoid-shaped bag, which fits into the trunk or “boot” of the vehicle to maximize space and organize and protect the cargo and the vehicle.

The Leather Dedicated Containers and Holders for Porsche Carrera GT Automobiles, when imported with these vehicles, are to be classified with the Porsche Carrera GT motor vehicles in heading 8703. They are items which complete the fully equipped vehicles.

The applicable heading for the Leather Dedicated Containers and Holders for Porsche Carrera GT Automobiles, will be heading 8703 Harmonized Tariff Schedule of the United States (HTS), which provides for Motor cars and other motor vehicles designed for the transport of persons (other than those of heading 8702), including station wagons and racing cars. The rate of duty will be 2.5% ad valorem.

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 Robert DeSoucey at 646-733-3008.


Robert B. Swierupski

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