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HQ W968298

OCTOBER 11, 2006



TARIFF NO.: 8544.30.0000

Gary Gessler
Sandler & Travis Trade Advisory Services, Inc. 36555 Corporate Drive, Suite 400
Farmington Hills, MI 48331

RE: Steering Roll Connector

Dear Mr. Gessler:

In a letter to the Director, National Commodity Specialist Division, U.S. Customs and Border Protection (CBP), New York, dated June 23, 2006, on behalf of Furukawa North America APD, Inc., you inquire as to the classification of a steering roll connector (“SRC”) under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA).

You propose classification of the SRC in a provision of heading 8537, HTSUS, as a base equipped with two or more apparatus of heading 8535 or 8536 for electric control or the distribution of electricity. In a telephone discussion on July 14, 2006, members of my staff advised you of CBP’s preliminary opinion that the SRC does not distribute electricity for tariff purposes; rather, it transmits or conducts electrical signals. In email transmittals, dated July 18 and September 11, 2006, you provided additional technical information in support of your proposed classification.


The SRC is a device that transmits electrical current from the steering column of a motor vehicle to electrical components in the steering wheel and back. The primary circuits are for the air bag with additional circuits for options that could be included in the steering wheel such as cruise control, radio, horn, turn signals, etc. Also referred to as a clockspring, the SRC is mounted between the steering wheel and steering column
and consists of an eight-conductor flat ribbon-type insulated copper cable in a 2-piece circular plastic housing, that makes an electrical connection to eight conductors within the steering wheel. The cable makes a transition into 2 multi-conductor pigtail cables, each in a yellow rubber sleeve. These cables attach to the electrical components in the steering wheel. On the under side of the SRC is a multi-conductor connector that a wiring harness plugs into. This wiring harness continues down the steering column, extending the wires from the SRC to the vehicle’s Electronic Control Unit (ECU). Included in the assembly are what you refer to as electrical hubs or bus bars that are actually flat wire connectors. The coiled design of the SRC allows the cable to expand and contract as the steering wheel makes three or four complete rotations in either direction, thus reducing the stress on the electrical conductors.

The HTSUS provisions under consideration are as follows:

Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity,:

8537.10 For a voltage not exceeding 1,000 V:

8537.10.90 Other

Insulatedwire, cable,and other insulated electric conductors, whether or not fitted with connectors;:

Ignition wiring sets and other wiring sets of a kind used in vehicles, aircraft or ships


Whether the SRC distributes electricity for tariff purposes.


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.

The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official interpretation of the Harmonized System at the international level. While not legally binding and, therefore not dispositive, the ENs provide a commentary on the scope of each heading of the HTSUS and are thus useful in ascertaining the classification of merchandise under the Harmonized System. CBP believes the ENs should always be consulted. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (Aug. 23, 1989).

You maintain that the SRC is classifiable as a base equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity, in subheading 8537.10.90, HTSUS. This is because the bus bars and the connectors are both classified in heading 8536 as electrical apparatus for making connections to or in electrical circuits, for a voltage not exceeding 1,000 V, and the principal use of the SRC is to distribute electricity. You cite as authority HQ 966188, dated May 17, 2004, which classified the 3-in-1 steering column switch in subheading 8537.10.90, HTSUS. This device consisted of three individual switches, each provided for in heading 8536, in a common housing, principally used for electric control. You discount the applicability of heading 8544, HTSUS, as insulated wire, cable, and other insulated electric conductors, whether or not fitted with connectors. You maintain that wiring harnesses are provided for in subheading 8544.30.00, HTSUS, as ignition wiring sets and other wiring sets of a kind used in vehicles, aircraft or ships, and the SRC is not a wiring harness.

The term distribute, derived from the term in heading 8537, is not defined in the HTSUS, nor is it described in the ENs. The term, therefore, is to be construed according to its common and commercial meanings which are presumed to be the same. Nippon Kogasku (USA), Inc. v. United States, 69 CCPA 89, 673 F.2d 380 (1982). Common and commercial meaning may be determined by consulting dictionaries, lexicons, scientific authorities and other reliable sources. C.J. Tower & Sons v. United States, 69 CCPA 128, 673 F.2d 1268 (1982). The New Oxford American Dictionary, Second Edition, defines distribute as “to give shares of (something); deal out,” and distribution as “the action of sharing something out among a number of recipients.” The function of distribution is “to receive electric power from large, bulk sources and to distribute it to consumers at voltage levels and with degrees of reliability that are appropriate to the various types of users.” The Standard Handbook for Electrical Engineers, Fourteenth Edition, Donald G. Fink and H. Wayne Beaty, authors.

In the present case, the SRC has an equal number of insulated wires with connectors from the steering wheel to the connectors in a wiring harness in the steering column. These wires are for the airbag, horn and other accessories that may include cruise control and radio. Each module has its individual wires coming into and out of
the steering wheel. If one wire were connected to all the modules within the steering wheel one could say it was apportioning or distributing power to all the modules. However, the SRC has an 8-conductor flat ribbon insulated cable that makes an electrical connection to 8 conductors within the steering wheel. This cable makes a transition into two round pigtail cables with individual connectors. Each conductor, therefore, completes a separate connection and cannot be said to distribute or share power to a number of components.

We find that simply transmitting voltage signals through a single conductor does not constitute the distribution of electricity. In fact, it is the vehicle’s ECU that distributes or apportions electricity. The ECU processes the electrical impulses it receives, determines through its microprocessor what adjustments are indicated for each module, then distributes electrical signals back to the modules, signaling the necessary adjustments. We find that the SRC constitutes an insulated electric cable fitted with connectors and used as a conductor in electrical machinery or apparatus. It therefore meets the terms of heading 8544. CBP’s classification of clocksprings, clockspring cases and steering rotary connectors in subheading 8544.30.0000, HTSUSA, has been consistent and longstanding. See NY D84682, dated December 3, 1998, NY D84422, dated December 4, 1998, and NY J80466, dated February 25, 2003.


Under the authority of GRI 1, the steering roll connector is provided for in heading 8544. It is classifiable in subheading 8544.30.0000, HTSUSA. The column one, general rate of duty under this provision is 5 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUSA and the accompanying duty rates are provided on the World Wide Web at www.usitc.gov/tata/hts.


Robert Altneu
for Gail A. Hamill, Chief
Tariff Classification and Marking Branch

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