CLA-2-87:RR:NC:1:MM 101 F88921
Mr. Robert J. Resetar
Porsche Cars North America, Inc.
980 Hammond Drive
Suite 1000
Atlanta, GA 30328
RE: The tariff classification of a steel washer from Germany.
Dear Mr. Resetar:
In your letter dated June 21, 2000, you requested a tariff classification ruling.
You have described your submitted sample, part # 996.343.107.03, as a steel washer. It is approximately 6 cm in total diameter, 3 mm in thickness and has a 1.4 cm diameter hole in the center. The washer has a curved shape that when set on a flat surface, rises approximately 1 cm. The washer will be used in two locations on a shock absorber strut. The first location is at the top of the strut, used in conjunction with a hex nut that secures the strut to the mounting. In the second location, the washer is used as a spacer between the bottom side of the mounting and a rubber stop. Your submitted sample will be returned to you as requested.
The design features of this washer do not appear to have the characteristics of “parts of general use” washers that have been described within the explanatory notes of heading 7318. It is not a small thin disc intended to be placed to protect a part. It has a conical design which appears to permit some flexibility of movement. In addition, its design feature functions as a spacer to fill a gap. It is specifically designed to function in a Porsche shock absorber strut and would not have a practical general use function as a washer.
The applicable subheading for the steel washer will be 8708.99.7060, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Parts for suspension systems…Other. The duty rate will be 2.5% ad valorem.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of this 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 212-637-7035.
Sincerely,
Robert B. Swierupski
Director
National Commodity
Specialist Division