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NY M82900

May 16, 2006

CLA-2-85:RR:NC:N1:112 M82900


TARIFF NO.: 8544.30.0000

Ralph Garcia
Manager, Customs Compliance
Mitsubishi Motors North America, Inc.
6400 Katella Ave.
Cypress, CA 90630-5208

RE: The tariff classification of a plastic coil, insulated wire and cable from Japan

Dear Mr. Garcia,

In your letter dated April 17, 2006, you requested a tariff classification ruling.

The item concerned is a Clock Spring. It is a round coil of plastic strip encased inside a piece of round, hard plastic with a hole in the middle. Attached to the hard plastic enclosure are four cables, harnessed together in sets of two, each cable containing multiple wires; one cable contains four individually insulated wires. All the cables and wires are fitted with connectors on their ends.

The purpose of the item is, when attached to a vehicle steering wheel assembly, to limit the steering radius of the wheel and to connect the steering assembly to various control and operational apparatus within the vehicle; e.g., air bag, radio, etc.

You propose in your letter that the Clock Spring is classifiable in subheading 8543.89.9795 (replaces subheading 8543.89.9695 effective April 1, 2006) of the Harmonized Tariff Schedule of the United States (HTSUS) which provides for "Electrical apparatus , having individual functions, not specified or included elsewhere ". The term "individual functions", for classification purposes, is defined in Explanatory Note 84.79 (B) (ii) to the Harmonized Tariff System. The Explanatory Notes (ENs) represent the official interpretation of the tariff at the international level and facilitate classification under the HTS by offering guidance in understanding the scope of the headings and the GRIs. EN 84.79 (B) states that "[items] are to be regarded as having "individual functions" provided that this function:

(ii) does not play an integral and inseparable part in the operation of such machine, appliance or entity.

The Clock Spring's plastic coil does play "an integral and inseparable part in the operation" of the steering assembly in that it limits the steering radius and returns the steering wheel to its original operating position upon release of the wheel. The Clock Spring's insulated cables and wires are also "integral and inseparable" as they provide the electrical connections allowing the steering assembly to not only operate as intended, but coordinate its operation with the entirety of the vehicle; therefore, the Clock Spring is excluded from classification in HTSUS heading 8543.

In addition, the Clock Spring is not classifiable as part of a vehicle in Chapter 87 of the HTSUS based on Note 2.(f) to Section XVII (in which Chapter 87 resides): "the expressions "parts" and "parts and accessories" do not apply to Electrical machinery or equipment (Chapter 85)".

The applicable classification subheading for the Clock Spring will be 8544.30.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Insulated wire, cable , whether or not fitted with connectors, : other wiring sets of a kind used in vehicles ”. The rate of duty will be 5%.

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 Richard Laman at 646-733-3017.


Robert B. Swierupski

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