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NY R04510

August 2, 2006

CLA-2-73:RR:E:NC:N1:118 R04510


TARIFF NO.: 7318.19.0000

Mr. Ralph Garcia
Manager, Customs Compliance
Mitsubishi Motors North America Inc.
6400 Katella Avenue
Cypress, CA 90805

RE: The tariff classification of “Nut, Front, Bumper” from Japan.

Dear Mr. Garcia:

In your letter dated July 28, 2006, you requested a tariff classification ruling.

The item you have described, part number MU435004, is referred to as a Nut, Front, Bumper or Nut insert. It is a round EPDM rubber casing that flares out at one end. There is a hole in the center that goes through the part. Inside the hole, at one end, is an internally threaded steel insert. The nut, front, bumper/nut insert will secure the plastic license plate garnish to the plastic bumper fascia. It is designed to protect the bumper fascia from distortion due to over-tightening and control vibration.

The applicable subheading for the Nut, Front, Bumper/Nut Insert will be 7318.19.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: threaded articles: other. The duty rate will be 5.7% ad valorem.

Consideration was given to classifying this product under subheading 7318.16.0085, HTSUS, as you have suggested. However, since this item functions as a threaded insert rather than as a nut, your suggested classification is deemed inappropriate.

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 Kathy Campanelli at 646-733-3021.


Robert B. Swierupski

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