The tariff classification of automobile seat arm assemblies from Japan.

N105302 May 26, 2010 CLA-2-94:OT:RR:NC:N4:433 CATEGORY: Classification TARIFF NO.: 9401.90.1085 Daniel Cannistra Crowell and Moring LLP 1001 Pennsylvania Avenue Washington, DC 20004 RE: The tariff classification of automobile seat arm assemblies from Japan. Dear Mr. Cannistra: In your letter dated May 12, 2010, on behalf of Aisin Holdings of America, you requested a tariff classification ruling. Illustrations, diagrams and description have been provided for automobile seat arm assemblies, identified as part numbers 432514-10180, 432516-10140, 441605-10050, 441605-10060, 441607-10060 and 441607-10070. The seat arm assemblies are comprised of a frame, plastic covering, bracket, and pivot bearing that allows the arm to be rotated. The seat arm assemblies adjust the position of the seat arm to recline or store. Each of the identified part numbers serve the identical function and represent front/rear/left/right variations and model variations. You advise on behalf of your client that the seat arm assemblies are designed specifically and exclusively as components for automobile seats. We disagree with your statement that the seat will not function without the seat arm assemblies. Per the specification sheets provided there appears to be no electronics or manual devices within the arm assemblies that would enable the seat/s to move forward or back, or up or down. The applicable subheading for the automobile seat arm assemblies, will be 9401.90.1085, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Seats… and parts thereof: Parts: Of seats of a kind used for motor vehicles, Other." The 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 Neil H. Levy at (646) 733-3036. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division