Mr. John F. Jäger
Toyota Tsusho America, Inc.
702 Triport Road
Georgetown, Kentucky 40324
RE: The tariff classification of automotive parts: Dust Cover Strut, Headrest Adjuster, Lumbar Knob Adjuster, Sensor, Seatbelt Warning Occupant Detection, and Vertical Adjuster Handle from Japan
Dear Mr. Jäger:
In your letter dated January 23, 2002 you requested a tariff classification ruling.
You submitted pictures of each of the following automotive parts:
Part 48559-33010 – Dust Cover Strut (Metal and covered with flexible plastic material) – The dust cover is assembled on the automotive strut module. There is one by each wheel and it assembles next to the shock to protect the car. The Tier 1 supplier describes the part as a low bearing, which the finished assembly is supplied to Toyota Motor Manufacturing. In the supplied picture the part is a circular metal ring with a plastic covering.
Part 71970-47010-B2 – Headrest Adjuster – Seat (plastic) – The color-coded headrest adjuster is assembled into the top portion of the seat. The actual headrest will be inserted through the headrest adjuster in the seat. The headrest is adjusted manually to the occupant’s preference. The button is depressed to move the headrest up or down by pushing or pulling.
Part 72457 – 18010-A1 Lumbar Knob Adjuster – seat (plastic) – This color coded lumbar knob is located on the side of the automotive seat to manually adjust the lumbar area of the back by turning the knob clockwise or counter-clockwise to the occupant’s preference.
Part 89953-45020 – Sensor, Seatbelt Warning Occupant Detection (electrical) – this sensor is assembled into the automotive seat and detects the presence of an occupant by weight/pressure when the vehicle is on or started. If an occupant is detected, and the seatbelt is not fastened the fasten seatbelt warning light is illuminated and/or blinks. The light will continue to illuminate and/or blink until the passenger seatbelt is properly fastened.
Part 72525-47020-B0 – Vertical Adjuster Handle-Seat (plastic) – The color coded handle is assembled on the side of an automotive seat which assists the occupant to manually adjust the vertical position of the seat to the occupant’s preference. The seat pivots on a vertical axis frontward or backward.
The applicable subheading for the Sensor, Seatbelt Warning Occupant Detection will be 8512.20.4040, Harmonized Tariff Schedule of the United States (HTS), which provides for Electrical lighting or signaling equipment (excluding articles of heading 8539), windshield wipers, defrosters and demisters, of a kind used for cycles or motor vehicles; parts thereof: Other lighting or visual signaling equipment: Visual signaling equipment…For the vehicles of subheading 8701.20 or heading 8702, 8703, 8704, 8705 or 8711. The rate of duty will be 2.5% ad valorem.
The applicable subheading for the Dust Cover Strut 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 suspensions systems…Other. The rate of duty will be 2.5% ad valorem.
The applicable subheading for the Headrest Adjuster, Lumbar Knob Adjuster, and Vertical Adjuster Handle will be 9401.20.0090, Harmonized Tariff Schedule of the United States (HTS), which provides for Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Seats of a kind used for motor vehicles…Other. The rate of duty will be Free.
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 646-733-3008.
Robert B. Swierupski