The tariff classification of automobile parts: two (2) Hooks, Parcel Strap from Japan

NY R00320 May 7, 2004 CLA-2-83:RR:NC:MM:101 R00320 CATEGORY: Classification TARIFF NO.: 8302.30.3060 Mr. Ralph Garcia Mitsubishi Motors North America, Inc. 6400 Katella Avenue Cypress, California 90630 RE: The tariff classification of automobile parts: two (2) Hooks, Parcel Strap from Japan Dear Mr. Garcia: In your letter dated April 27, 2004 you requested a tariff classification ruling. You submitted drawings depicting two (2) Hooks, Parcel Strap which are replacement service automobile parts. You state in your narrative that the first type, are hooks which are used as replacement parts for certain older Mitsubishi models and are more basic. The second type, are hooks, which are used on newer Mitsubishi models and consist of more components. The first part: Hook, Parcel Strap MB235985 - consists of a steel loop, an anchor bracket, a bolt, and a plastic silencer. These hooks are anchored down to the body of the vehicle, in the cargo area of certain sport utility vehicles. The purpose of the hooks is to provide an anchor point in the cargo area to secure goods with a cargo net or other means. The second part: Hook, Parcel Strap MN157246XA - consists of a nickel plated steel ring, a steel bracket, a bolt, a fiber washer, a plastic silencer, a plastic bolt cover and plastic bezel. All of these components are assembled into the plastic bezel and then anchored down to the body of the vehicle, in the cargo area of certain Mitsubishi sport utility vehicles. The purpose of the hook is to provide an anchor point in the cargo area to secure goods with a cargo net or other means. Additionally, the plastic bezel is designed to match the interior trim of the vehicle to enhance the aesthetic appearance of the cargo area. You state that based upon the characteristics of these components you believe that they are properly classified under HTS 8708.29.5060, which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories of bodies (including cabs): Other: Other…Other. The duty rate would be 2.5% ad valorem. We disagree with your proposed classification because these parts are specifically provided for as fittings or mountings for a motor vehicle. The applicable subheading for the Hook, Parcel Strap MB235985 and Hook, Parcel Strap MN157246XA 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, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like; base metal hat racks, hat-pegs, brackets and similar fixtures; castors with mountings of base metal; automatic door closers of base metal; 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 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 646-733-3008. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division