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NY N012611

June 14, 2007



TARIFF NO.: 8708.80.6590

Laurie Peach, Manager-Customs
American Honda Motors
1919 Torrance Blvd
Torrance, CA 90501-2746

RE: The tariff classification of a vehicle part from Japan

Dear Ms. Peach,

In your letter dated June 11, 2007, you requested a tariff classification ruling.

The item concerned is the Right Rear Knuckle (Part # 52210-SDC-A60).

The knuckle is a multi-purpose component of the vehicle, in that it integrated into several systems on the vehicle. First, it acts as an integral part of the vehicle suspension. It attaches to the various suspension arms and functions in conjunction with other suspension components to suspend the vehicle’s drive train above the wheels. Second, it incorporates an integrated spindle which acts as a mounting shaft for the right rear bearing assembly hub unit. Finally, it functions as a mounting base for the right rear caliper sub-assembly, and the right rear disk brake, which is a component of the vehicle’s braking system.

In your Request, you propose classification of the knuckle in subheading 8708.50.5150 of the Harmonized Tariff Schedule of the United States (HTSUS) which provides for “Parts of motor vehicles : Drive axles with differential : Drive axles with differential : For vehicles of heading 8703: Non-driving axles”.

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". The primary function of the Right Rear Knuckle (Part number 52210-SDC-A60) is as a linkage which aids in suspending a vehicle drivetrain above its wheels (and hub assembly).

The applicable classification subheading for the Right Rear Knuckle (Part # 52210-SDC-A60) will be 8708.80.6590, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts 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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