CLA-2-85:OT:RR:NC:1:120
Mr. Joseph A. Infante Fist Enterprises, LLC
801 South Olive Avenue
West Palm Beach, FL 33401
RE: The tariff classification of a vehicle starter system
Dear Mr. Infante: In your letter dated January 15, 2015, you requested a tariff classification ruling on merchandise, which you plan to export. A sample was submitted with your letter and will be returned.
The merchandise under consideration is a vehicle starter system, which is known as the “Fist Smart Start Unit.”
This system is composed of various components, i.e., a control module; a passive capacitance swipe sensor; a sensor-to-module cable; a relay; a relay interface; an installer programmer; and an end user programmer. It operates off the vehicle’s 12 Volt DC (12VDC) electrical system and prevents the vehicle from being started by anyone other than the authorized user. The system uses a relay interface that is wired into the vehicle’s electrical system and serves as a connector for the relay. The relay itself overrides the function of the factory relay. The control module (or base unit) is the “brains” of the system and is connected to the sensor by the sensor-to-module cable, as well as to the relay interface. The installer programmer is used to set the amount of time the starter cranks. The end user programmer is used by the end user to add or delete users of the vehicle starter system. The system is capable of internally storing 24 users. The system functions by measuring the difference in resistance of the user’s fingerprint ridges as the finger is swiped across the sensor. Once the fingerprint is verified, the sensor transmits a signal to the control module, thereby allowing the vehicle to be started.
This system meets the terms of Legal Note 4 to Section VXI, Harmonized Tariff Schedule of the United States (HTSUS), which states “Where a machine (including a combination of machines) consists of individual components (whether separate or interconnected by piping, by transmission devices, by electric cables or by other devices) intended to contribute together to a clearly defined function covered by one of the headings in chapter 84 or chapter 85, then the whole falls to be classified in the heading appropriate to that function.” In this instance, all the components of this vehicle starter system contribute together to the clearly defined function of starting the vehicle.
You state that this vehicle starter system is manufactured in the United States with the intention of exporting to other countries. Please be advised that classification rulings issued by this office are applicable to the product in question when imported into the United States. Since you also plan to export this product, it is recommended that you seek a ruling from the designated customs service of that country prior to export.
The applicable subheading for the vehicle starter system, identified as the “Fist Smart Start Unit,” will be 8537.10.9060, HTSUS, which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity, . . . : For a voltage not exceeding 1,000 V: Other: Other: Programmable controllers.” 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 Denise M. Fainger at [email protected]. Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division