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NY N024192




March 13, 2008

CLA-2-87:OT:RR:NC:N1:101

CATEGORY: CLASSIFICATION

TARIFF NO.: 8708.94.7550, 8301.20.0060

Paula Johnson, Customs Analyst
Alps Automotive, Inc.
1500 Atlantic Boulevard
Auburn Hills, MI 48326-1500

RE: The tariff classification of motor vehicle parts from Mexico

Dear Ms. Johnson,

In your letter dated February 22, 2008, you requested a tariff classification ruling.

The items under consideration are two (2) Steering Column Electrical Assembly Modules, which you have identified as part numbers SANAH1860A and SANAH1862A, and one (1) Lock Housing, which you have identified as part number ANA011017A.

Item one, part number SANAH1860A, is a steering column electrical assembly module that is used to form a portion of the vehicle’s steering column assembly and to control various electrical functions in a motor vehicle. Part SANAH1860A is comprised of a clock spring (including electrical wiring and connectors), power tilt and telescope switch, stalk switch that controls headlights and turning signals, stalk switch that controls windshield washer/wiper, ignition switch, steering angle sensor, lock housing, bracket, and various hardware.

Item two, part number SANAH1862A, is a steering column electrical assembly module that is used to form a portion of the vehicle’s steering column assembly and to control various electrical functions in a motor vehicle. Part SANAH1862A is comprised of a clock spring (including electrical wiring and connectors), power tilt and telescope switch, turn signal/fog light switch, windshield washer/wiper switch, ignition switch, Pk3 satellite, steering angle sensor, lock housing, bracket and various hardware parts.

The applicable classification subheading for the two (2) Steering Column Electrical Assembly Modules, part numbers SANAH1860A and SANAH1862A will be 8708.94.7550, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts[of]motor vehicles : Other parts: Steeringparts: Parts: For other vehicles: Other: Other”. The rate of duty will be 2.5%.

Item three, Lock Housing, part number ANA011017A, is an ignition locking assembly. It consists of an electronic power lock (EPL), EPL solenoid, driver cam actuator, housing, cover, lock bolt, springs and various hardware parts. You stated in our telephone conversation of March 7, 2008 that the locking assembly is designed to prevent the removal of the ignition key, should the vehicle be engaged in any gear other than “Park”.

In your Ruling Request, you propose classification of the Lock Housing, part number ANA011017A, in subheading 8708.94.7500 of the HTSUS which provides for “Parts[of]motor vehicles : Other parts: Steeringparts: Parts: For other vehicles: Other: Other”.

Classification of goods in the Harmonized Tariff Schedule of the United States (HTSUS) is governed by the General Rules of Interpretation (GRIs). GRI 1. states, “ ... classification shall be determined according to the terms of the headings ... ".

General Note 3. (h) (vi) to the HTSUS states, “ ... a reference to “headings” encompasses subheadings indented thereunder.” Subheading 8301.20 of the HTSUS provides for “Locks of a kind used on a motor vehicle.”

The applicable classification subheading for the Lock Housing, part number ANA011017A will be 8301.20.0060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “locks (keyelectrically operated), of base metal,parts: Locks of a kind used on a motor vehicle: Other”. The rate of duty will be 5.7%.

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 Steering Column Electrical Assembly Modules, part numbers SANAH1860A and SANAH1862A, contact National Import Specialist Richard Laman at 646-733-3017. If you have any questions regarding Lock Housing, part number ANA011017A, contact Barbara Kaiser at 646-733-3024.

Sincerely,

Robert B. Swierupski
Director,

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