CLA-2-87:RR:NC:MM:101 B89510

Mr. Edward Woehr
SUBARU-ISUZU AUTOMOTIVE, INC.
5500 State Road 38 East
Lafayette, IN 47903

RE: The tariff classification of automotive parts from Japan

Dear Mr. Woehr:

In your letter dated September 8, 1997, you requested a tariff classification ruling.

The first item concerned (shown below), the Stabilizer Assembly, is a claw-shaped piece of steel measuring 1«"L X 2"W. It has a piece of white, hard plastic with a piece of black, soft textile glued to the back of it's claws.

The function of this item is to act as a support for a vehicle window as it is raised and lowered; the item, itself, is attached to a vehicle's inner door panel.

The applicable subheading for the Stabilizer Assembly (Part #61270C) will be 8708.29.5060, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of . . . motor vehicles . . . : Other parts and accessories of bodies: Other: Other: Other. The rate of duty will be 2.7% ad valorem.

The second item (shown below), the Webbing Guide, is a formed piece of black steel measuring 3¬"L X 1 "W. It has a white, plastic coating over the bend of it's bottom portion.

The function of this item is to act as a guide to a vehicle's seatbelt shoulder strap. It attaches to the center pillar on each side of a vehicle's interior.

The applicable subheading for the Webbing Guide (Part #s 64765H & 64765I) will be 8708.29.5060, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of . . . motor vehicles . . . : Other parts and accessories of bodies: Other: Other: Other. The rate of duty will be 2.7% ad valorem.

The third item (diagram shown below), the Battery Bottom Sheet, is a rectangular piece of hard plastic with a full upright rim.

The function of this item is to insulate a vehicle's battery from the metal battery tray; it fits over the metal battery tray and the vehicle battery sits in it.

The applicable subheading for the Battery Bottom Sheet (Part #894405-0300) will be 8708.99.8080, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of . . . motor vehicles . . . : Other parts and accessories: Other: Other: Other: Other: Other. The rate of duty will be 2.7% ad valorem.

The fourth item (diagram shown below), the Battery Clamp, is an hourglass-shaped piece of steel with another piece of steel, bent at a 45ø degree angle, attached perpendicularly near one end.

The function of this item is to secure a vehicle battery so that it stays within the battery tray; the item clamps on top of the vehicle battery and is tightened by a bolt and tension rod.

The applicable subheading for the Battery Clamp (Part #897163-1030) will be 8708.99.8080, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of . . . motor vehicles . . . : Other parts and accessories: Other: Other: Other: Other: Other. The rate of duty will be 2.7% ad valorem.

The fifth item (diagram shown below) is the Air Cleaner Assembly; it is a plastic case, comprised of top and bottom (or Cap and Case) which houses an Air Filter Element and is located within a vehicle engine. In your letter, you indicate that the Air Cleaner Assembly will be imported either with or without the Air Filter Element.

The function of this item is to clean the air within a vehicle engine.

The applicable subheading for the Air Cleaner Assembly (Part #s 897064-5570, 897138-9620, 897111-4230) imported with the Air Cleaner Element will be 8421.31.0000 , Harmonized Tariff Schedule of the United States (HTS), which provides for Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for gases: Intake air filters for internal combustion engines. The rate of duty will be 2.7% ad valorem.

The applicable subheading for the Air Cleaner Assembly (Parts #s 897064-5570, 897138-9620, 897111-4230) imported without the air filter element will be 8421.99.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Parts: Other . . . Other. The rate of duty will be 1.6% ad valorem.

The sixth item (diagram shown below) is the Support Assembly; it is a piece of steel which is attached to the rear and rear bumper of a vehicle.

The function of this item is to stabilize a vehicle's rear bumper.

The applicable subheading for the Support Assembly (Part #894170-4181) will be 8708.10.3050, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of . . . motor vehicles . . . : Bumpers and parts thereof: Bumpers: Other. The rate of duty will be 2.7% ad valorem.

The last item (shown below) is the Stay Assembly; it is a curved piece of gold-colored steel with a hole at one end and a dark brown, hard plastic clip snapped on to the other end. The item measures 1¬"L X 1¬"W.

The function of this item is to support a vehicle ignition's wiring at various points between the spark plugs and distributor cap. This item is bolted to the vehicle engine at several places.

The applicable subheading for the Stay Assembly will be 8708.99.8080, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of . . . motor vehicles . . . : Other parts and accessories: Other: Other: Other: Other: Other. The rate of duty will be 2.7% ad valorem. You state that all of the items will be used in or on the Isuzu Rodeo Sports Utility Vehicle or the Subaru Legacy automobile. You further state that the exporters for these items will be Isuzu Motors Japan and Fuji Heavy Industries [Subaru] and that they will be entered into the U.S. through the Port of Indianapolis, Indiana.

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 212-466-5667.


Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division