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NY R00488





July 1, 2004
CLA-2-85:RR:NC:MM:101 R00488

CATEGORY: CLASSIFICATION

TARIFF NO.: 8512.90.6000

Mr. Dennis Forhart - Senior Manager
PricewaterhouseCoopers LLP
400 Renaissance Center
Detroit, Michigan 48243-1507

RE: The tariff classification of Headlamp Bezels used on semi-trucks from the United States

Dear Mr. Forhart:

In your letter dated June 23, 2004 you requested a tariff classification ruling on behalf of your client Freightliner.

You submitted technical drawings of various Headlamp Bezels used on semi-trucks.

Part Number: A06-20737 - Bezel/Lens Assy - is a bezel/lens assembly that has three cavities, two of which will be where the headlamp units come through. The third cavity will house a side bulb and is closed off by an acrylic lens. The bezel assembly will be mounted onto the vehicle’s body and serve as trim around the headlamp assembly.

Part Number: 06-32242 - Bezel-Headlight - is a headlamp bezel that is oblong in shape and made of ABS plastic. The Bezel attaches to the vehicle’s body and functions as trim or finishers around the headlamp assembly.

Part Number 17-13803 - Bezel-Headlamp A-Series - is a headlamp bezel that is oblong in shape and made of ABS plastic. The Bezel attaches to the vehicle’s body and functions as trim or finishers around the headlamp assembly.

You state that you believe that these three Headlamp Bezel Assemblies are correctly classified under HTS 8708.29.5060, which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories of bodies (including cabs): Other: Other...Other. We disagree with your proposed classification because even though these items are attached to the body they are actually parts of the lighting equipment of the semi-truck.

The applicable subheading for the Bezel/Lens Assy - Part A06-20737, Bezel-Headlight - Part 06-32242, and Bezel-Headlamp A-Series - Part 17-13803 will be 8512.90.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for Electrical lighting or signaling equipment (excluding articles of heading 8539), windshield wipers, defrosters and demisters, of a kind used for cycles and motor vehicles; parts thereof: Parts: Of lighting equipment: Other.

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 646-733-3008.

Sincerely,

Robert B. Swierupski
Director,

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