The tariff classification of a vehicle part from an unspecified country

N034429 August 18, 2008 CLA-2-87:OT:RR:NC:N1:101 CATEGORY: Classification TARIFF NO.: 8708.99.8180 Ms. Lora Mayo-Brown, NA Classification/Import Supervisor Robert Bosch LLC 8101 Dorchester Road N. Charleston, SC 29418-2906 RE: The tariff classification of a vehicle part from an unspecified country Dear Ms. Mayo-Brown, In your letter dated July 22, 2008, you requested a tariff classification ruling. The item concerned is the Front Corner Module Assembly (GMT900). It is a roughly circular piece of metal containing an assembly of seven (7) vehicle parts: a steering knuckle, a splash shield, a hub & bearing assembly, a wheel speed sensor, a brake rotor, a brake caliper and bolts to attach and hold the brake caliper, brake rotor and the bearings inside the bearing portion of the hub & bearing assembly. The various functions of the Front Corner Module Assembly (GMT900) are to serve as a connection between a vehicle’s suspension arms and its wheel and tire assembly to allow flexibility, to administer braking torque, to send wheel speed information to the anti-lock brake control module and to transmit drive torque from the CV (constant velocity) shaft to the vehicle wheel. You propose in your Ruling Request that the Front Corner Module Assembly (GMT900) be classified in subheading 8708.30.5090 of the Harmonized Tariff Schedule of the United States (HTSUS) which provides for “Brakes … ; parts thereof: For other vehicles: 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 8708.30.5090 of the HTSUS only provides for “Brakes … ; parts thereof”; the Front Corner Module Assembly (GMT900) contains not only brake parts, but parts for steering (steering knuckle) and wheel attachment and movement (hub & bearing assembly). A classification in subheading 8708.30.5090 would not accommodate either the steering knuckle or hub & bearing assembly, both of whose functions are necessary for the operation of a vehicle. The applicable classification subheading for the Front Corner Module Assembly (GMT900) will be 8708.99.8180, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts … of … motor vehicles … : Other parts … : Other: Other: Other: Other: Other: Other”. The rate of duty will be 2.5%. 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 the ruling, contact National Import Specialist Richard Laman at 646-733-3017. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division