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
New York Seaport