CLA-2-90:S:N:N1:104 889323

Mr. Frank S. Ward
Wall Shipping Co., Inc.
P.O. Box 20022
Air Cargo Building
Washington-Dulles Int'l Airport
Washington, D.C. 20041

RE: The tariff classification of tachographs from Germany

Dear Mr. Ward:

In your letter dated July 29, 1993, you requested a tariff classification ruling on behalf of Argo Instruments, Inc..

The tachographs - Models 1308, 1310, 1315 and 1318 - capture information such as a vehicle's speed, idling, distance traveled, rpm, PTO or engine brake activation, doors open or closed, emergency sirens and lights and brake applications. Each unit is a combination tachometer, speedometer, odometer, clock and recorder. During a trip, the tachograph continuously records the vehicle operating information onto circular charts inside the unit by means of a sapphire tipped stylus. The tachograph is installed in the dash or elsewhere in the cab where it is easily visible to the driver. When installed in-dash, the unit can be substituted for the OEM speedometer. From a review of your submitted literature, principal measurements appear to be speed and rpm's. The applicable subheading for the tachographs - Models 1308, 1310, 1315 and 1318 - will be 9029.20.4080, Harmonized Tariff Schedule of the United States (HTS), which provides for Revolution counters, production counters, taximeters, odometers, pedometers and the like; speedometers and tachometers, other than those of heading 9014 or 9015; stroboscopes; parts and accessories thereof: Speedometers and tachometers; stroboscopes: Other speedometers and tachometers...Other. The rate of duty will be Free.

You also inquired as to the tariff classification of parts of these tachographs. In the absence of specific information, we are unable to provide you with a ruling on this matter. In general, parts of tachographs which are not goods provided for in any of the other headings of chapters 84, 85, 90 or 91, nor excluded from chapters 84, 85, 90 or 91, may be classifiable in the same heading as the article of which they are a part provided they are solely or principally used with such article (see Notes 1 and 2 of Section XVI, Note 1 of chapter 84, Note 1 of chapter 85, Notes 1 and 2 of chapter 90 and Notes 1 and 4 of chapter 91, HTS).

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.


Jean F. Maguire
Area Director
New York Seaport