CLA-2 CO:R:C:G 082334 JMH
KI Industries, Inc.
P.O. Box 166
Elmhurst, Illinois 60126-9998
RE: Appliance knobs and fittings
Dear Ms. Goltermann:
Your letter of December 28, 1987, requesting a
classification ruling under the Harmonized Tariff Schedule of the
United States (HTSUSA) for appliance knobs and fittings has been
referred to this office for a reply.
The merchandise in question are ten knobs and fittings for
various household appliances to be imported from Hong Kong and
Taiwan. Parts 5383 and 5445, temperature control knobs, are
made of ABS plastic and are used with refrigerators. Five parts
are principally used with washing machines: parts 5350, a
plastic control knob; part 5353, a chrome plated ABS plastic part
of a control knob; part 5460, a chrome plated ABS plastic end
cap; part 5447, an ABS plastic and aluminum knob skirt; and part
5500, a plastic push button knob for indicating the machine
cycle. Two of the pieces are control knobs used principally with
dryers: part 5442, made of plastic and part 5443, made of
plastic and aluminum. Part 5045, a chrome plated plastic control
knob is used equally with washers and dryers.
Under which headings of the HTSUSA are these appliance knobs
and fittings to be classified?
LAW AND ANALYSIS:
The classification of merchandise under the HTSUSA is
governed by the General Rules of Interpretation (GRI's). GRI 1
states in part that "for legal purposes, classification shall be
determined according to the terms of the headings and any
relative section or chapter notes...". When classifying goods
according to use, "the controlling use is the principal use."
Additional U.S. Rule of Interpretation 1, HTSUSA.
Section XVI, HTSUSA, covers "Machinery and Mechanical
Appliances...Parts and Accessories of Such Articles." Since the
items to be classified are parts of domestic-type machines or
mechanical appliances, the headings and notes within Section XVI
apply to these goods. Section XVI, Note 2, HTSUSA, states that
"parts of machines...are to be classified according to the
(a) Parts which are goods included in any of the
headings of chapter 84 and 85...are in all cases
to be classified in their respective headings;
(b) Other parts, if suitable for use solely or
principally with a particular kind of machine, or with
a number of machines of the same heading...are to be
classified with the machines of that kind...
(c) All other parts are to be classified in heading
8485 or 8548."
It is the opinion of this office that each of the instant
parts are to be used principally with particular machines; thus,
the parts should be classified within the headings for those
machines. Parts 538 5383 and 5445 are classifiable within
subheading 8418.99.00, HTSUSA, as "Refrigerators,
freezers...parts thereof...Parts...Other..." The rate of duty is
2.9 percent ad valorem.
The washing machine parts, 5350, 5353, 5447, 5460, and 5500
are classified within subheading 8450.90.00, HTSUSA, as
"Household- or laundry-type washing machines...parts
thereof...Parts." The rate of duty is 5.1 percent ad valorem.
The dryer parts, 5442 and 5443 are classified within
subheading 8451.90.00, HTSUSA, as "Machinery (other than machines
of heading 8450) for...drying...parts thereof...Parts...". The
rate of duty is 5.1 percent ad valorem.
Finally, part 5045, since it has no principal use, is
classified within subheading 8485.90.00, HTSUSA, as "Machinery
parts, not containing electrical connectors, coils, contacts or
other electrical features and not specified or included
elsewhere in this chapter...Other." The rate of duty is 5.7
percent ad valorem.
Parts 5383 and 5445 are classified within subheading
8418.99.00, HTSUSA. The rate of duty is 2.9 percent ad valorem.
Parts 5350, 5353, 5447, 5460 and 5500 are classified within
subheading 8450.90.00, HTSUSA, with a tariff rate of 5.1 percent
ad valorem. Part 5442 and 5443 are classified within subheading
8451.90.00, HTSUSA, with a tariff rate of 5.1 percent ad valorem.
Part 5045 is classified within subheading 8485.90.00, HTSUSA.
The rate of duty is 5.7 percent ad valorem.
John Durant, Director
Commercial Rulings, Division