The tariff classification of automobile Rubber Grommets and Metal Tubes/Caps from China

NY H82114 June 12, 2001 CLA-2-83:RR:NC:MM:101 H82114 CATEGORY: Classification TARIFF NO.: 4016.99.6050, 8302.30.3060 Ms. Barbara Sivek World Commerce Services, Inc. 830 Dillon Drive Wood Dale, Illinois 60191 RE: The tariff classification of automobile Rubber Grommets and Metal Tubes/Caps from China Dear Ms. Sivek: In your letter dated May 15, 2001 you requested a tariff classification ruling. You submitted samples of items that are used in the connecting of headlights to an automobile. The wiring for the headlights goes through the connectors to guide and protect them. The Rubber Grommets are made of Neoprene synthetic rubber and have various holes in them for various sizes and amounts of wires that go through them. They fit tightly into the connectors so that the wires do not move or cross. The Metal Tubes/Caps, made of die cast aluminum, are threaded either on both ends or only on one end. These items are used to hold the rubber grommet (above) firmly in place while connecting the automobile’s headlight to the vehicle. You suggest that the Rubber Grommets should be classified under HTS 4016.93.1050 dutiable at 2.5% ad valorem, which provides for Other articles of vulcanized rubber other than hard rubber: Other: Gaskets, washers and other seals: Of a kind used in the automotive goods of chapter 87…Other. We disagree with your proposed classification because the Rubber Grommets do not function as gaskets to prevent the passage of matter. You suggest that the Metal Tubes/Caps should be classified under HTS 8536.61.0000 dutiable at 2.7% ad valorem, which provides for Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits (for example, switches, relays, fuses, surge suppressors, plugs, sockets, lamp-holders, junction boxes), for a voltage not exceeding 1,000 V: Lamp-holders, plugs and sockets: Lamp-holders. We disagree with your proposed classification because the Metal Tubes/Caps are not electrical apparatus. The applicable subheading for the Rubber Grommets will be 4016.99.6050, Harmonized Tariff Schedule of the United States (HTS), which provides for Other articles of vulcanized rubber other than hard rubber: Other: Other: Other: Other: Other…Other. The rate of duty will be 2.5% ad valorem. The applicable subheading for the Metal Tubes/Caps will be 8302.30.3060, Harmonized Tariff Schedule of the United States (HTS), which provides for Base metal mountings, fittings and similar articles suitable for furniture, staircases,…,coachwork,…; and base metal parts thereof: Other mountings, fittings and similar articles suitable for motor vehicles; and parts thereof: Of iron or steel, of aluminum or of zinc: Other. The rate of duty will be 2% ad valorem. 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, National Commodity Specialist Division