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NY N025051

March 31, 2008



TARIFF NO.: 8708.99.8180

Robert Scott, Logistics Analyst
Williams Controls, Inc.
14100 SW 72nd Street
Portland, OR 97224-8009

RE: The tariff classification of Electronic Foot Pedal Assembly from China

Dear Mr. Scott,

In your letter dated March 20, 2008, you requested a tariff classification ruling.

The item under consideration is an Electronic Foot Pedal Assembly (EPFA) which you have identified as Model WM-526 (Part # 351548). The EPFA is designed for use in all Caterpillar Scrapers, Off-Highway Dump Trucks, Small Wheel Loaders and Small Compactors. The EPFA’s base plate is configured at a 45 degree angle to mount to the cab floor. The EFPA incorporates am integrated rotary pedal position sensor and harness that is proprietary for use with Caterpillar engines. In your Ruling Request you state that the assembly meets FMVSS-124 and may be used in On-Highway applications.

The applicable classification subheading for the Electronic Foot Pedal Assembly, Model WM-526 (Part # 351548) will be 8708.99.8180, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Partsofmotor vehicles : Other parts: Other: Other: Other: 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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