Ms. Lora Mayo-Brown
Robert Bosch LLC
8101 Dorchester Road
Charleston, South Carolina 29418

RE: The tariff classification of an electronic control unit and other components for an antilock brake system from Germany

Dear Ms. Mayo-Brown:

In your letter dated July 10, 2012 you requested a tariff classification ruling. Descriptive information and samples were submitted. Samples will be returned as requested.

The articles in question are described as a “Generation 8 ECU (Electronic Control Unit) attached to the Hydraulic unit”, a “Generation 8 ECU stand alone (Ceramic Substrate)”, a “Generation 8 ECU housing” and a “Generation 8 ECU attached to the housing”.

Based on the information made available, the “Generation 8 ECU (Electronic Control Unit) attached to the Hydraulic unit” is a solenoid actuated valve that controls the direction and volume of hydraulic fluid, i.e. brake fluid, to braking components in response to control signals from the ECU.

The “Generation 8 ECU housing” is the housing for the ECU and incorporates the solenoids and other electrical components necessary to actuate the hydraulic unit.

The “Generation 8 ECU attached to the housing” comprises the ECU and its housing and is assembled ready for attachment to the hydraulic unit.

The “Generation 8 ECU stand alone (Ceramic Substrate)” is the central processor for the antilock braking system.  It is a hybrid integrated circuit.  The manufacturing process begins with a ceramic insulating substrate upon which a thick film circuit has been formed, allowing for resistors to be produced at the same time.  The substrate is then populated with semiconductors by mounting them onto the surface of the substrate.

The applicable subheading for the ECU housing and ECU attached to the housing will be 8412.90.9015, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of other hydraulic power engines and motors. The rate of duty is free.

The applicable subheading for the ECU attached to the hydraulic unit will be 8481.20.0050, HTSUS, which provides for other valves for hydraulic or pneumatic transmissions. The rate of duty will be 2 percent ad valorem.

The applicable subheading for ceramic substrate (hybrid integrated circuit) will be 8542.31.0000, HTSUS, which provides for electronic integrated circuits: processors and controllers, whether or not combined with memories, converters, logic circuits, amplifiers, clock and timing circuits, or other circuits.  The rate of duty is free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at

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 Kenneth T. Brock at (646) 733-3009.


Thomas J. Russo
National Commodity Specialist Division