CLA-2-83:OT:RR:NC:N1:121

Ms. Nicole M. Jenkins
Crowell & Moring LLP
1001 Pennsylvania Avenue, NW
Washington, DC 20004-2595

RE: The tariff classification of a vehicle door bushing from Japan

Dear Ms. Jenkins:

In your letter dated August 26, 2010, you requested a tariff classification ruling on behalf of Aisin Holdings of America Inc. The submitted sample will be retained by this office.

The merchandise under consideration is a vehicle door bushing made of copper. It is a round, unthreaded, flanged fitting that does not incorporate ball bearings or moving parts. It weighs 11 grams and has an outer diameter of 21 mm, an inner diameter of approximately 12 mm and a depth of 7.5 mm. The bushing is designed to be used in the sliding door roller assembly of a motor vehicle. The sliding door roller assembly supports and guides a door on a minivan or other vehicle to open and slide along a rail. The primary function of the bushing within the sliding door roller assembly is to serve as a spacer that ensures a proper fit between the lower door roller and a bracket. You have indicated that it also serves to connect and facilitate the movement of these parts.

You state in your letter that you believe the bushing should be classified in subheading 8302.30.3060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other mountings, fittings and similar articles suitable for motor vehicles, and parts thereof, of iron or steel, of aluminum or of zinc, other. Please note, however, that mountings/fittings of 8302.30, HTSUS, made of copper are classified in subheading 8302.30.60, HTSUS, which provides for mountings/fittings of base metal with the exception of iron, steel, aluminum or zinc.

The applicable subheading for the copper bushing will be 8302.30.6000, HTSUS, which provides for Base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the likeā€¦and base metal parts thereof, other mountings, fittings and similar articles suitable for motor vehicles; and parts thereof, other. The rate of duty will be 3.5 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