CLA-2-87:RR:NC:MM:101 K87744

Mr. Rick Safsten
Autoliv ASP, Inc.
3350 Airport Road
Ogden, Utah 84405

RE: The tariff classification of a Steering Wheel Armature from China and Brazil

Dear Mr. Safsten:

In your letter dated July 2, 2004 you requested a tariff classification ruling.

You submitted a sample that we are returning to you of a Steering Wheel Armature, identified on the Shipping Memo you submitted as: “601280800D, Nissan ZW/IWZW/WZW Armature”. You state that this item is the metal frame that is subsequently covered with plastic or rubber material to create the steering wheel used in many different types of motor vehicles.

You state that you believe that the correct classification for the Steering wheel Armature is HTS 8708.99.7360, which provides for Parts for Steering Systems: Other. We disagree with your proposed classification because this unfinished steering wheel is specifically provided for in the tariff as a steering wheel.

The applicable subheading for the Steering Wheel Armature will be 8708.94.5000, 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: Steering wheels, steering columns and steering boxes: For other vehicles. The rate of duty 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 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.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division