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NY N011623

May 25, 2007



TARIFF NO.: 8708.80.6590

Laurie Peach, Manager-Customs
American Honda Motors
1919 Torrance Blvd.
Torrance, CA 90501-2722

RE: The tariff classification of vehicle parts from Japan

Dear Ms. Peach,

In your letter dated May 22, 2007, you requested a tariff classification ruling.

The item under consideration is described as a knuckle. Per your submitted Diagram A, the subject part is the R. FR. KNUCKLE, (Part number 51210-SL0-902). This item is a part of the front suspension/steering/wheel mount system on a rear-wheel drive vehicle.

It is located between the upper and lower suspension arms and serves three purposes. First, it acts as a mounting base for the Hub Bearing Assembly; the front hub-bearing assembly bolts directly to the knuckle.

Second, it acts as a suspension component that bridges the upper and lower suspension arms and, thereby, is the means for attaching the wheel assembly to the suspension system.

Finally, it serves as a steering component. The knuckle pivots on its mounts to the upper and lower suspension arms in response to the angular motion of the power steering gear box, which is transmitted via the tie rod to the knuckle and serves to move the wheels during steering.

In your Request, you propose classification of the knuckle in subheading 8708.99.8180 of the Harmonized Tariff Schedule of the United States (HTSUS) which provides for “Parts of motor vehicles : Other parts : 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 drive train above its wheels". The primary function of R. F. KNUCKLE, (Part number 51210-SL0-902) is as a linkage which aids in suspending a vehicle drive train above its wheels (and hub assembly) - that it also pivots to allow steering of the wheels is a secondary function dictated simply by its location.

The applicable classification subheading for R. FR. KNUCKLE, (Part number 51210-SL0-902) 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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