The tariff classification of a vehicle control unit from Korea

N349032 May 23, 2025 CLA-2-85:OT:RR:NC:N2:212 CATEGORY: Classification TARIFF NO.: 8543.70.9860; 9903.01.25 Hae Jun Kwon Hyundai Motor Company 231, Yangjae-dong, Seocho-gu Seoul 06797 South Korea RE: The tariff classification of a vehicle control unit from Korea Dear Mr. Kwon: In your letter dated May 15, 2025, you requested a tariff classification ruling. The merchandise under consideration is identified as two models of the Advanced Driver Assistance System (ADAS) Park Electronic Control Unit (ECU), which are further identified by part numbers 99910-R6000 and 99910-CW400. You state that the two versions are virtually identical and function the same with the only difference being the shape of the bracket that is attached and used to mount the device within a vehicle. The subject device is comprised of a Printed Circuit Board Assembly (PCBA), which contains a microcontroller, vision processor, various transceivers, as well as other electrical components. This PCBA is housed within a plastic enclosure and incorporates a cooling fan assembly. As noted above, a metal bracket for installation is on the outside of the housing. In use, the subject ECU is placed within the vehicle and interfaces, through electrical connection, with various vehicle safety systems. These include a connection to the Parking Collision Avoidance System, the Parking Distance Warning System, the Remote Smart Parking Assist System, the Blind-Spot View Monitor, and the Surround View Monitor. Each of these systems provide different driver assistance functions such as warning the driver of obstructions when reversing, blind spot detection, remote parking assistance, as well as various others. The subject control unit collects information through the ultrasonic sensors and cameras within each of these systems, processes this information, and sends a signal to the appropriate location within the vehicle to affect an alert or response. We note that the control unit does not contain any sensors or cameras. In your request, you suggest that the correct classification for the control unit is 8543.70.9860, Harmonized Tariff Schedule of the United States (HTSUS). We agree. The applicable subheading for the ADAS Park ECU, part numbers 99910-R6000 and 99910-CW400, will be 8543.70.9860, HTSUS, which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other: Other: Other.” The general rate of duty will be 2.6% ad valorem. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 8543.70.9860, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Luke LePage at luke.lepage@cbp.dhs.gov. Sincerely, (for) Steven A. Mack Director National Commodity Specialist Division