Mr. Mitchell Neriah
Mitchell Neriah Customs Consulting Services
415 S. Prospect Ave., Suite 110
Redondo Beach, California 90277
RE: The tariff classification of Various Components (“Pipe Comp”, “Cable”, “Spring”, “Bracket Comp”) of Seat Adjusting Mechanisms and Seats Used in Motor Vehicles from Japan
Dear Mr. Neriah:
In your letter dated January 31, 2002 you requested a tariff classification ruling on behalf of Imasen Bucyrus Technology, Inc. (“IB Tech).
You submitted photographs of various components of seat adjusting mechanisms and seats used in motor vehicles. You state that the complete seat adjusting mechanism is referred to by IB Tech as a “Full Seat Device.” The Full Seat Device is the entire base metal assembly upon which the seat is mounted, and allows for the seat occupant to adjust the seat position forward or reverse, adjust the seat back recline position, and in some cases, raising or lowering seat height in relation to the auto floor. The seat back and the seat bottom are attached to the Full Seat Device, and the Full Seat Device is fastened to the floor by a bracket.
The first item, “PIPE COMP” is used on a Full Seat Device. It is a base metal tube with flanges on each end to attach to a recliner bracket on the left and right sides of the Full Seat Device. There is an additional one-inch flange welded on the tube near one end. Near the other end of the tube are two small drilled holes. The PIPE COMP functions to support the overall structure of the Full Seat Device by connecting the left and right slide rails and recliner brackets. It also serves as an anchor for mounting the third item, the “SPRING”. You state that the PIPE COMP is specifically designed for and used solely with automobile seats, and cannot be used in any other application.
The second item, “CABLE”, is a power transmission shaft used with an electrically operated Full Seat Device. The Full Seat Device uses an electric motor and slide rails with a threaded adjusting mechanism to adjust the seat position forward or reverse. The power of the electric motor is used to turn the adjusting mechanism, and moves the seat forward or reverse along the rails. Although both the left and right slide rails have the threaded adjusting mechanism, only one electric motor is used to power them both. The Cable is a flexible power transmission shaft, with a rectangular cross sectional shape, which is connected between the electric motor mounted on the left side rail and the threaded adjusting mechanism on the right side rail. The Cable transmits the motor’s power from the motor to the adjusting mechanism on the far rail. Thus, when the motor is activated, the adjusting mechanisms in both rails are activated simultaneously. You state that the Cable is specifically designed for and used solely with automobile seats, and cannot be used in any other application.
The third item, “SPRING”, is a steel spring in the form of a strait (sic) rod with one end hooked 180 degrees back towards the middle, and the other end bent at a 90 degree angle. The Spring is installed on the Pipe Comp. The 180 degree hooked end is inserted into the welded flange on the Pipe Comp. The other end of the Spring is inserted through two pre-drilled holes in the Pipe Comp. The protruding end of the spring is then bent back to secure it in place in the Pipe Comp. The spring functions in the Full Seat Device as a spring to apply upward force on the seat bottom to assist the height adjust electric motor when activated. As the Pipe Comp rotates, it builds a load on the Spring to push upward, and thus assist the power of the electric motor. You state that the Spring is specifically designed for and used solely with automobile seats, and cannot be used in any other application.
The fourth item, “BRACKET COMP”, is a base metal bracket which is used to secure an auto seat to a Full Seat Device. The bracket has four pre-drilled holes, two of which allow the bracket to be fastened by bolts to the Full Seat Device. The other two holes allow the bracket to be fastened to the seat. You state that the Bracket Comp is specifically designed for and used solely with automobile seats, and cannot be used in any other application.
The applicable subheading for the “PIPE COMP” and the “CABLE” will be 8708.29.5060, 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 of bodies (including cabs): Other: Other…Other. The rate of duty will be 2.5% ad valorem.
The applicable subheading for the “BRACKET COMP” will be 8302.30.3060, Harmonized Tariff Schedule of the United States (HTS), which provides for Base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like; base metal hat racks, hat-pegs, brackets and similar fixtures; castors with mountings of base metal; automatic door closers of base metal; and base metal parts thereof: Other mountings, fittings and similar articles suitable for motor vehicles; and parts thereof: Of iron or steel, of aluminum or zinc…Other. The rate of duty will be 2% ad valorem.
The applicable subheading for the “SPRING” will be 7320.90.5060, Harmonized Tariff Schedule of the United States (HTS), which provides for Springs and leaves for springs, of iron or steel: Other: Other…Other. The rate of duty will be 2.9% 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 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