CLA-2-83:OT:RR:NC:N1:121
Mr. Robert J. Resetar
Porsche Cars North America Inc.
980 Hammond Drive, Suite 1000
Atlanta, Georgia 30328
RE: The tariff classification of a motor vehicle mounting from Germany
Dear Mr. Resetar:
In your letter dated July 10, 2008, you requested a tariff classification ruling. The sample you have submitted will be returned to you.
The merchandise under consideration is described as a “Bonded Rubber Mounting.” It is a threaded steel stud measuring approximately 4 cm in length and 0.5 cm in diameter with a bushing made from EDPM rubber affixed at its center. One side of the bushing is covered by a metal cap to prevent deformation when in use. The mounting serves to secure two components together while also providing vibration dampening. You note in your letter that this product has multiple applications throughout the vehicle, such as connecting two brackets together, connecting the radiator mounting bracket to the radiator and connecting an air valve to the intake manifold.
You indicate that you believe the mounting should be classified in one of the following subheadings: 4016.99.5500, 7318.15.5090 or 7318.19.0000. While the mounting does “fasten goods so that they can readily be disassembled without damage,” it performs an additional function of vibration dampening. Accordingly, the mounting would not be considered a threaded fastener of heading 7318. It appears from your description that the primary purpose of this product is to mount, support or attach components together. Consequently, the essential character of this composite good is imparted by the steel component. The mounting, therefore, meets the terms of subheading 8302.30, HTSUS, which covers base metal mountings, fittings and similar articles suitable for motor vehicles.
The applicable subheading for the mounting will be 8302.30.3060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for base metal mountings, fittings and similar articles, other mountings, fittings and similar articles suitable for motor vehicles; and parts thereof, of iron or steel, of aluminum or of zinc, other. The rate of duty will be 2 percent ad valorem.
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 http://www.usitc.gov/tata/hts/.
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 Barbara Kaiser at 646-733-3024.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division