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NY G82486





October 12, 2000

CLA-2-87:RR:NC:MM:101 G82486

CATEGORY: CLASSIFICATION

TARIFF NO.: 7317.00.7500, 7318.15.8045, 7320.90.5060, 8708.29.5060

Mr. Jesus Antonio Pena
Import/Export Supervisor
TRW Safety Systems, Inc.
3801 Ursula
McAllen, Texas 78503

RE: The tariff classification of Parts of an Auto Seat Belt Retractor from Canada

Dear Mr. Pena:

In your letter dated September 6, 2000 you requested a tariff classification ruling.

You submitted parts that will be assembled into an Auto Seat Belt Retractor. You also submitted a blue print and an indented Bill of Material. Its primary purpose is to join with the Buckle Assembly to support restraint.

You stated that each part of the Auto Seat Belt Retractor is shipped in bulk from Canada. Then the necessary parts are selected and assembled into the complete Auto Seat Belt Retractor. Therefore, each part must be broken out and classified separately. The following parts were submitted:

LABEL # PART NO. PART DESCRIPTION

3 312185C Retractor Base
6 31306A Sleeve
7 31468B Cam
9 316087B Pawl
10 33979A Spring Cover Assy
13 ZUDL Webbing - Graphite
18 36301D Bracket
19 33500 Weight
22 351010C Cinch Housing
23 353016B Backing Plate
28 326009 Tongue Assy
29 359120DMGH D Ring Cover
30 327124C D Ring Assy
32 32765A Anchor
37 39141A Bolt
38 361151B Retractor Cover
41 39138 Pia Bolt
44 358090A Shipping Clip

You also submitted a plastic bag with various small components, which you referred us to the submitted blue print.

Item Label # 3 - Retractor Base is a stamped piece of metal, approximately 5 1/2" L x 21/2" W x 2 1/2" H - with numerous, variously sized holes punched out.

Item Label # 6 - Sleeve is a tubular shaped piece of metal with a groove cut out. The part measures approximately 2 1/4" L x 1 3/8" W.

Item Label # 7 - Cam is a circular, saw-tooth stamped piece of metal with a diameter of approximately 2 1/2".

Item Label # 9 - Pawl is an irregularly - shaped, stamped piece of metal approximately 2 1/2" L x 1" W.

Item Label # 10 - Spring Cover Assy is a circular piece of plastic approximately 2 1/2" in diameter.

Item Label # 13 - Webbing is a cut-to-length piece of webbing material.

Item Label # 18 - Bracket is a "[" shaped piece of plastic approximately 2" L x 2 1/2" W.

Item Label # 19 - Weight is a circular piece of metal approximately 5/8" L x 7/16" in diameter. There is an approximately 1/8" hole through the center of the piece of metal.

Item Label # 22 - Cinch Housing is an irregularly shaped piece of plastic approximately 2 1/2 L x 2" W x 5/16" D.

Item Label # 23 - Backing Plate is an irregularly shaped piece of plastic approximately 2 1/2" L x 1 15/16" W.

Item Label # 28 - Tongue Assy - is the part of a seat belt that snaps into the buckle. It is made of metal and plastic.

Item Label # 29 - D Ring Cover - is a plastic cover that covers the D Ring Assembly.

Item Label # 30 - D Ring Assy - is a metal D shaped Ring.

Item Label # 32 - Anchor - is an "L" shaped piece of metal approximately 1 1/2" x 1 1/2". There is a circular hole and a "D" shaped cut out on each side of the "L".

Item Label # 37 - Bolt - is a threaded bolt.

Item Label # 38 - Retractor Cover - is a plastic cover that contains parts of the Seat Belt Retractor Mechanism.

Items Label # 41 - Pia Bolt and Label # 44 - Shipping Clip - we are unable to locate those parts.

There is also an unlabeled red colored three-pronged plastic item we are unable to identify.

In the plastic bag of parts there are:

A plastic cover for possibly a tack; a metal disc approximately 3/4" in diameter with a circular cut-out; a flat plastic disc (sticker # 15) approximately 1 7/8" in diameter; a piece of plastic (sticker # 31) approximately 5 1/4" long with a protrusion on each end; a circular metal rod approximately 3 5/8" long with a 1/2"groove cut on one end; an irregularly shaped piece of plastic approximately 1 1/2" long; a threaded metal bolt; a metal spring; two metal parts (stickers #4 & 17); and a tack.

The applicable subheading for the Tack will be 7317.00.7500, Harmonized Tariff Schedule of the United States (HTS), which provides for Nails, tacks,, of iron or steel, whether or not with heads of other material, but excluding such articles with heads of copper: Other: Of two or more pieces. The duty rate will be 0.9% ad valorem.

The applicable subheading for two items you term as "Bolts", are actually Socket Screws will be 7318.15.8045, Harmonized Tariff Schedule of the United States (HTS), which provides for Screws, bolts, nuts, coach screws,, and similar articles, of iron or steel: Threaded articles: Other screws and bolts, whether or not with their nuts or washers: Other: Having shanks or threads with a diameter of 6 mm or more: Other: Socket Screws: Other. The duty rate will be 8.5% ad valorem.

The applicable subheading the Spring will be 7320.90.5060, Harmonized Tariff Schedule of the United States (HTS), which provides for Springs and leaves for springs, of iron or steel: Other: OtherOther. The duty rate will be 2.9% ad valorem.

The applicable subheading the Retractor Base, Sleeve, Cam, Pawl, Spring Cover Assy, Webbing-Graphite, Bracket, Weight, Cinch Housing, Backing Plate, Tongue Assy, D Ring Cover, D Ring Assy, Anchor, Retractor Cover, will be 8708.29.5060, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories of bodies: Other: OtherOther. The duty rate will be 2.5% ad valorem.

The applicable subheading for the following parts contained in the plastic bag: plastic cover; a metal disc; a flat plastic disc (sticker # 15); a piece of plastic (sticker # 31); a circular metal rod; an irregularly shaped piece of plastic; a threaded metal bolt; a metal spring; and a tack., will be 8708.29.5060, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories of bodies: Other: OtherOther. The duty rate will be 2.5% ad valorem.

Your inquiry does not provide enough information for us to give a classification ruling on the Pia Bolt, Shipping Clip, Parts Labeled #4 and #17 (contained in the plastic bag), and a red colored, three-pronged plastic item. We are unable to locate Label # 41 - Pia Bolt and Label # 44 - Shipping Clip. We are unable to determine the function and use of Parts Labeled # 4 and # 7. We do not know the function and use of the (unlabeled) red three-pronged plastic item. Your request for a classification ruling should include a diagram and a detailed description how each part is used. When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.

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 Robert DeSoucey at 212-637-7035.

Sincerely,

Robert B. Swierupski
Director,

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