The tariff classification of inner and outer stainless steel bushing sleeves from South Korea, Japan and China

N298282 July 16, 2018 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7326.90.8688 Ms. Maria E. Celis Neville Peterson LLP One Exchange Plaza 55 Broadway, Suite 2602 New York, NY 10006 RE: The tariff classification of inner and outer stainless steel bushing sleeves from South Korea, Japan and China Dear Ms. Celis: In your letter dated June 22, 2018, you requested a tariff classification ruling on behalf of your client Koide Tennessee, Inc. Photographs and specification sheets for the bushing sleeves were submitted for our review. The subject articles are identified as seamless stainless steel inner and outer bushing sleeves that are used for automobile engine mountings or in suspension systems. You stated in your letter that the bushing sleeves “are produced in various sizes, and measure in outside diameter from 10-100 mm, with a wall thickness of 1.2 to 10 mm. They are made from seamless mechanical grade stainless steel tubing which has been cut to lengths of 8 to 200 mm and chamfered to make them suitable for use as bushing sleeves.” The length and diameter of each bushing sleeve corresponds to specifications dictated by auto producers. In their condition as imported, the sleeves have been machined to their final dimensions and chamfered. You indicated that they have been advanced to the point where they have no commercial use other than to act as parts of anti-vibration bushings in automobiles. You suggested classification for the inner and outer bushing sleeves under heading 8708, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts and accessories of the motor vehicles of headings 8701 to 8705. This offices does not agree with your proposed classification because the inner and outer bushing sleeves are neither parts nor accessories of motor vehicles. The subject sleeves are components of bushings that could be used in different automotive applications. “A subpart of a particular part of an article is more specifically provided for as a part of the part than as a part of the whole.” C.F. Liebert v. United States, 60 Cust. Ct. 677, 686-87, 287 F.Supp. 1008, 1014 (1968). You stated that the bushings are used in engine mounting systems and in suspension systems. Depending on the construction of the bushing and its function, classification of the sleeve may vary in headings 4016, 8302, 8483, and 8708. As a result, classification of the inner and outer sleeves in heading 8708 is precluded. The applicable subheading for the inner and outer stainless steel bushing sleeves will be 7326.90.8688, HTSUS, which provides for other articles of iron or steel, other…other. The rate of duty will be 2.9 percent ad valorem. 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 https://hts.usitc.gov/current. 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 Ann Taub at ann.taub@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division