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NY N008994

April 10, 2007



TARIFF NO.: 8708.80.6590

Ralph Garcia, Mgr.-International Trade Compliance Mitsubishi Motors North America Inc.
6400 Katella Ave.
Cypress, CA 90630-5208

RE: The tariff classification of vehicle parts from Japan

Dear Mr. Garcia,

In your letter dated March 28, 2007, you requested a tariff classification ruling.

The items concerned are knuckles used in the steering and suspension systems of vehicles:

LH Knuckle (Part number MR403403) is attached to the front axle of a vehicle and provides a mounting surface for the Hub Assembly, on which the front wheels are mounted. The Knuckle pivots and contains an opening which allows connection of the CV axle shaft to the wheel hub and bearing assembly.

RR AXLE LH Knuckle (Part number MR992531) is attached to the rear axle of a vehicle and provides a mounting surface for the rear wheels of rear-wheel drive vehicles; on vehicles that have only front-wheel drive, the Knuckle is attached to a spindle that connects to the rear axle.

In your Request, you propose classification of the LH Knuckle (Part number MR403403) in subheading 8708.99.8180 of the Harmonized Tariff Schedule of the United States (HTSUS) which provides for “Parts of motor vehicles : Other: Other: Other: Other: Other: Other”.

Classification of goods in the Harmonized Tariff Schedule of the United States (HTSUS) is governed by the General Rules of Interpretation (GRIs). GRI 1. states, “ ... classification shall be determined according to the terms of the headings ... ".

General Note 3. (h) (vi) to the HTSUS states, “ ... a reference to “headings” encompasses subheadings indented thereunder.”. Subheading 8708.80 of the HTSUS provides for "Suspension systems and parts thereof ". The Road & Track Illustrated Automotive Dictionary (Revised Edition, 2000) defines "suspension" as "the linkages used to suspend a car's drivetrain above its wheels". Axles are part of a vehicle drivetrain.

The LH Knuckle (Part number MR403403) is a linkage which aids in suspending a vehicle drivetrain above its wheels.

The applicable classification subheading for LH Knuckle (Part number MR403403) and RR AXLE LH Knuckle (Part number MR992531) will be 8708.80.6590, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of motor vehicles : Suspension systems and parts thereof : Parts: Other: Other: Other”. The rate of duty will be 2.5%.

Duty rates are provided for your convenience and are subject to change. The text of the most recent Harmonized Tariff Schedule of the United States and the accompanying duty rates are provided on the World Wide Web at http://ww.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 Richard Laman at 646-733-3017.


Robert B. Swierupski

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