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NY M82012

April 14, 2006

CLA-2-85:RR:NC:1:110 M82012


TARIFF NO.: 8537.10.9070; 8544.30.0000

Ms. Donna Jkeldsen
Kostal of America, Inc.
25325 Regency Drive
Novi, MI 48375

RE: The tariff classification of a steering column module from Mexico.

Dear Ms. Jkeldsen:

In your letter dated March 3, 2006 you requested a tariff classification ruling.

The merchandise under consideration is a steering column module (P/N 014164XX), printed circuit board (PCB) cassette (P/N 04311241) and a multifunction switch (P/N 01150042). In addition to the complete steering column module, you also requested classification of the cassette and multifunction switch if imported separately. A sample of the complete steering column module (P/N 014164XX) with the cassette and multifunction switch installed was submitted with you ruling request.

The complete steering column module, P/N 014164XX, is a round plastic collar measuring approximately 6” deep with a diameter of 4½” and will be assembled over the steering column between the steering wheel and dashboard. This module incorporates two combination lever switches, one for the operation of the vehicles cruise control system with its multi-position lever and push button, and a second lever, P/N 01150042, also a multifunction lever switch. This second lever is a 3-in-1 multifunction switch that moves in four different directions to control the left/right turn signals and high/low beam headlight settings. At the end of this lever is a rotary switch used to control the windshield wipers with adjustable rain delay speed settings and a push button to activate the windshield washer system. Within the steering column module is P/N 04311241, a flat wire assembly housed within a round plastic cassette measuring approximately 4¼” in diameter and ½” thick. This cassette fits into the steering column module and allows free rotation of the steering wheel without interruption of the attached electrical wiring harness that completes all connections from controls mounted on the steering wheel to the vehicles electrical system. There is no PCB within this cassette. There is 7 feet of flat ribbon cable permanently connected to a 9-pin plug at one end, which will be inserted into a socket within the steering column module. The opposite end of the flat ribbon cable is permanently connected to a 6” wiring harness that protrudes out from the cassette with three individual connectors. The cassette assembly is dedicated for use with the steering column module.

Classification of parts is determined by Legal Note 2 to Section XVI, Harmonized Tariff Schedule of the United States (HTSUS), which states “Subject to note 1 to this section, note 1 to chapter 84 and to note 1 to chapter 85, parts of machinesare to be classified according to the following rules:

(a) Parts which are goods included in any of the headings of chapters 84 and 85are in all cases to be classified in their respective headings;

In understanding the language of the HTSUS, the Harmonized Commodity Description and Coding System Explanatory Notes may be utilized. The Explanatory Notes, although not dispositive, are to be used to determine the proper interpretation of the HTSUS. In part, Explanatory Note 85.44, HTSUS, states:

Provided they are insulated, this heading covers electric wire, cable and other conductors (e.g., braids, strip, bars) used as conductors in electrical machinery, apparatus or installations. . . .

Wire, cable, etc., remain classified in this heading if cut to length or fitted with connectors (e.g., plugs, sockets, lugs, jacks, sleeves or terminals) at one or both ends. The cassette assembly satisfies the above descriptions. The cassette is essentially insulated conductors with connectors.

The applicable subheading for the complete steering column module (P/N 014164XX) and the multifunction switch (P/N 01150042) imported separately will be 8537.10.9070, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Boards, panels, consolesand other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricityFor a voltage not exceeding 1,000 V: Other: Other: Other.” The general rate of duty will be 2.7 percent ad valorem.

The applicable subheading for the cassette assembly (P/N 04311241) will be 8544.30.0000, HTSUS, which provides for: “Insulated (including enameled or anodized) wire, cable (including coaxial 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.” The general rate of duty will be 5 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/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 Thomas Campanelli at 646-733-3016.


Robert B. Swierupski

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