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NY N013361

July 16, 2007



TARIFF NO.: 8537.10.9070

Mr. Martin W. Dooley
Multimodal International, Ltd.
2100 E. Devon Ave., Suite 102
Elk Grove Village, IL 60007

RE: The tariff classification of a power steering control module from Japan.

Dear Mr. Dooley:

In your letter dated June 22, 2007 you requested a tariff classification ruling on behalf of your client, Toyota Tsusho America.

The merchandise under consideration is the Power Steering Control Module (PSCM). The PSCM is a solid-state electronic module that monitors and determines the amount of power assist steering needed in a motor vehicle. The PSCM uses a combination of torque sensor inputs, vehicle speed input from the Engine Control Module (ECM), calculates system temperature and the steering calibration to determine the amount of steering assist needed. At low speeds more assist is provided for easy turning during parking maneuvers. At high speeds, less assist is provided for improved road feel and directional stability.

The Electric Power Steering (EPS) system utilizes a 12 volt brushed DC reversible servo motor to apply torque to the steering system. The motor assists steering through a worm shaft and reduction gear located in the steering column housing. The steering column has an input shaft, from the steering wheel to the torque sensor, and an output shaft, from the torque sensor to the steering shaft coupler. The input and output shafts are separated by a torsion bar, where the torque sensors are located. As the steering wheel rotates, signal voltage from torque sensors are received by the PSCM, which calculates, controls and delivers the amount of voltage necessary to power the electric servo motor. From the information you provided, the PSCM consists of a small housing containing integrated circuits of relays, Field Effect Transistors (FET) and other active and passive electrical components. The outside of the housing features several electrical connectors for connecting the PSCM to the vehicles electrical system, servo motor and various sensors. The operating voltage of the PSCM is 9-16V DC.

The applicable subheading for the Power Steering Control Module will be 8537.10.9070, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity: For a voltage not exceeding 1,000 V: Other: Other: Other.” The general rate of duty will be 2.7 percent ad valorem.

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 Thomas Campanelli at 646-733-3016.


Robert B. Swierupski

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