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NY R01636





April 8, 2005

CLA-2-87:RR:NC:MM:101 R01636

CATEGORY: CLASSIFICATION

TARIFF NO.: 8708.10.3010, 8708.10.3050, 8708.10.6050

Mr. Dennis Forhart
PricewaterhouseCoopers LLP
1420 Fifth Avenue
Suite 1900
Seattle, Washington 98101

RE: The tariff classification of Bumper Assemblies and Bumper Parts from the United States

Dear Mr. Forhart:

In your letter dated February 25, 2005 you requested a tariff classification ruling on behalf of your client Freightliner LLC.

You submitted drawings of Bumper Assemblies and Bumper Parts used on semi-trailer heavy trucks.

Bumper Assembly, Part Number A21-25541-014 – is a complete bumper assembly that is mounted to the vehicle’s frame. This assembly includes the front bumper section and two side sections that are shaped to fit the curvature of the cab body. The front section is fastened directly to the frame rails by steel bolts. The two side sections are fastened to the center section by means of cap screws. This item is not a stamping. The main function of this part is to absorb shock and prevent damage in the event of a collision.

Complete Front Bumper, Part Number A21-26669-001 – this bumper is a metal stamping that has been substantially worked after stamping. The bumper is made of stainless steel and aluminum. The main purpose of this article is to provide protection and to absorb shock from external obstructions or collisions.

Center Section of a Bumper Assembly, Part Number 680 880 13 70 – is the center section of a bumper assembly. When imported, the bumper does not include the bumper end sections, which attach to both ends of the center section. This bumper section is not a stamping, it contains welded components such as reinforcements and stiffeners that provide more rigidity.

End Section of a Bumper Assembly, Part Number A21-26500-003 – is made of steel and includes two reinforcement plates that allow it to attach to the center section of a bumper assembly.

Bumper Air Dampener, Part Number 22-44060-001 – is made of thermoplastic and its function is to deflect air from under the bumper assembly, in order to diminish the air drag caused under the semi-trailer truck while traveling at high speeds. The air dampener is attached to the bottom part of the front bumper beam by several bolts.

The applicable subheading for the Bumper Assembly and Complete Front Bumper will be 8708.10.3010, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Bumpers and parts thereof: BumpersStampings.

You state that you believe that the Bumper Air Dampener is 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: OtherOther. We disagree with your proposed classification because this part is more specifically classified as an other part of a bumper.

The applicable subheading for the Center Section of a Bumper Assembly, End Section of a Bumper Assembly and the Bumper Air Dampener will be 8708.10.6050, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Bumpers and parts thereof: BumpersParts of bumpersOther.

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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