CLA-2-87:S:N:N1:101-850403
Mr. John F. Cowen
Philip T. Cowen
Customhouse Brokers
1918 E. Elizabeth
Brownsville, TX 78520
RE: The tariff classification of motor vehicle accessories from
Mexico
Dear Mr. Cowen:
In your letter dated March 5, 1990, on behalf of Autotron,
Longmont, Co., you requested a tariff classification ruling. You
indicate that Autotron will be involved in assembly operations of
U. S. components in Mexico. You have submitted a sample of each
product you will import.
The radiator bug screen is comprised of a steel alloy
screen, polyester fabric, and eye grommets which fasten the
bugscreen to the front of a truck tractor. The article covers
the outside of the truck tractor radiator and is used to keep
insects from clogging the radiator.
The radiator cover is comprised of bonded polyester fabric,
a zipper, eye grommets that fasten the cover to a truck tractor
radiator, snaps, and a decal which is silk screened onto the
front of the cover. The article is used to cover the radiator
where it helps keep the engine warm in winter by allowing less
cold air to strike the radiator. The zipper portion of the cover
is opened to allow air in and closed to keep air out.
The applicable subheading for the truck tractor radiator bug
screen and cover will be 8708.29.0060, Harmonized Tariff Schedule
of the United States (HTS), which provides for parts and
accessories of motor vehicle bodies. The rate of duty will be
3.1 percent ad valorem.
Subheading 9802.00.80, HTS, provides a partial duty
exemption for articles assembled abroad in whole or in part of
fabricated components, the product of the United States, which
(a) were exported in condition ready for assembly without further
fabrication, (b) have not lost their physical identity in such
articles by change in form, shape, or otherwise, and (c) have not
been advanced in value or improved in condition abroad except by
being assembled and except by operations incidental to the
assembly process such as cleaning, lubricating, and painting.
All three requirements of subheading 9802.00.80, HTS, must
be satisfied before a component may receive a duty allowance. An
article entered under subheading 9802.00.80, HTS, is subject to
duty upon the full value of the imported assembled article less
the cost or value of such U. S. components, upon compliance with
the documentary requirements of section 10.24 of the Customs
Regulations (19 CFR 10.24).
If you want a ruling on the applicability of subheading
9802.00.80, HTS, for your specific merchandise, please address
your request to:
U. S. Customs Service
Office of Regulations and Rulings
1301 Constitution Ave., N.W.
Washington, DC 20229-0001
Indicate exactly what material is sent to Mexico, fully explain
the assembly process in Mexico, describe what job is performed by
Autotron, note where the cutting process takes place (in the U.
S. or Mexico), and list the value of the material that is sent to
Mexico and the value of the completed article.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport