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NY N023456




February 29, 2008

CLA-2-85:OT:RR:E:NC:N1:109

CATEGORY: CLASSIFICATION

TARIFF NO.: 8517.62.0050

Mr. Kit Johnson
Mercedes-Benz U.S. International, Inc.
One Mercedes Drive
Vance, AL 25490

RE: The tariff classification of central antennas from Germany and wheel antennas from Mexico

Dear Mr. Johnson:

In your letter dated February 18, 2008 you requested a tariff classification ruling.

The merchandise subject to this ruling is central antennas and wheel antennas. Your letter states that the central antennas and wheel antennas are installed on vehicles within the tire pressure monitoring (TPM) systems.

The entire TPM system consists of a TPM control unit, wheel sensors, a central antenna, and wheel antennas. The TPM control unit processes and evaluates data and the wheel sensors collect tire pressure and tire temperature. This ruling, however, pertains only to the central antennas and wheel antennas.

Each central antenna, which is installed in the center of each vehicle’s underfloor, receives tire pressure and tire temperature data from the wheel sensors. One sensor on each of the four wheels collects tire temperature and pressure data and forwards the data via 315 or 433 MHz radio frequency to the central antenna. The central antenna then forwards the data via conventional electrical wiring to the TPM control unit where the data is processed and evaluated.

One wheel antenna is installed in each rear wheel well (two installed per vehicle). Upon command from the TPM control unit, the wheel antenna transmits a 125 kHz radio frequency signal to its corresponding wheel sensor. The TPM control unit makes the decision as to when the wheel antenna should send a signal. There is no interaction between the vehicle’s driver and the wheel antenna. The wheel antenna has no RF reception capabilities.

The central antenna and the wheel antenna do not have the ability to gather and store data, maintain a maintenance log, make repairs or trouble shooting calculations, nor make data comparisons. The central antenna’s only function is to receive the radio signals from the four wheel sensors and forward the information via electrical wiring to the TPM control unit and the wheel antenna’s only function is to send a triggering RF signal to the wheel sensors upon command from the TPM control unit. As such, the central antenna and the wheel antenna do not have a secondary function.

The applicable subheading for the central antennas will be 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other." The rate of duty will be free.

The applicable subheading for the wheel antennas will be 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other." The general rate of duty will be free.

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 Linda M. Hackett at 646-733-3015.

Sincerely,

Robert B. Swierupski
Director,

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