CLA-2-84:OT:RR:NC:N1:102
Mr. Gary J. Wieckowski
ZF Group NAO
15811 Centennial Drive
Northville, MI 48188
RE: The tariff classification of a hydraulic and an elastomeric bushing and the components used in the manufacture of the bushings
Dear Mr. Wieckowski:
In your letter dated May 11, 2011 you requested a tariff classification ruling. Descriptive literature and illustrations were included with your submission.
The products you plan to import are a hydraulic bushing, an elastomeric bushing and the individual components that make up each complete bushing. The hydraulic and the elastomeric bushing are a type of vibration isolator. They are described as rubber-to-metal structures connected in between two members of a vibration system. The function of the bushings is to dampen the energy as it passes through them, resulting in noise reduction and vibration control. The bushings are principally used in suspension systems for automotive vehicles and trucks.
The hydraulic bushing includes an endcap, a travel limiter, a cage, an inner metal, a rubber component, an outer component and a glycol mixture. These parts can be made of different materials. The endcap and inner metal are made of either steel or aluminum. The travel limiter, the cage and the outer component are made of steel, aluminum or plastic. The rubber component is made from either natural rubber, EPDM (ethylene propylene diene monomer) synthetic rubber, nitrile synthetic rubber (NR) or butyl synthetic rubber (BR) while the glycol mixture consists of Ethylene glycol (80%) and water (20%).
The endcap secures the travel limiter in place and also serves as the interface to the mating part. The travel limiter partly controls the travel/action of the bushing. The cage along with the inner metal acts as a bonding surface for the rubber. The glycol mixture is the interior fluid that provides the hydraulic damping function while the rubber component performs some damping as well. In addition, the rubber component along with the outer component serves as a membrane to seal in the glycol mixture. Based on the information made available, the glycol mixture imparts the essential character to the hydraulic bushing.
The elastomeric bushing, like the hydraulic bushing, consists of an inner metal (steel or aluminum), a rubber component (natural rubber, EPDM synthetic rubber, nitrile synthetic rubber or butyl synthetic rubber) and an optional outer component (steel, aluminum or plastic). This bushing may also be designed or produced with an intermediate component made of steel, aluminum or plastic that acts as a bonding surface for the rubber component. However, unlike the hydraulic bushing, the elastomeric bushing does not include a glycol mixture which performs the damping function. The rubber component reduces noise, controls vibration and imparts the essential character to the bushing.
The applicable subheading for the hydraulic bushing will be 8487.90.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other machinery parts, not containing electrical connectors, insulators, coils contacts or other electrical features, and not specified or included elsewhere in Chapter 84. The rate of duty will be 3.9 percent ad valorem.
The applicable subheading for the elastomeric bushing, when made with natural rubber, will be 4016.99.3000, HTSUS, which provides for other articles of vulcanized rubber other than hard rubber: other: of natural rubber: vibration control goods of a kind used in the vehicles of headings 8701 through 8705. The rate of duty will be free.
The applicable subheading for the elastomeric bushing, when made with synthetic rubber, will be 4016.99.5500, HTSUS, which provides for other articles of vulcanized rubber other than hard rubber: other: other: vibration control goods of a kind used in the vehicles of headings 8701 through 8705. The rate of duty will be 2.5 percent ad valorem.
The applicable subheading for the endcap, the travel limiter, the cage, the inner metal, the intermediate component and the outer component, when imported separately, will be 8487.90.0080, HTSUS, which provides for other machinery parts, not containing electrical connectors, insulators, coils contacts or other electrical features, and not specified or included elsewhere in Chapter 84. The rate of duty will be 3.9 percent ad valorem.
The applicable subheading for the rubber component for both the hydraulic and elastomeric bushing, when made of natural rubber, will be 4016.99.3500, HTSUS, which provides for other articles of vulcanized rubber other than hard rubber: other: of natural rubber: other. The rate of duty will be free.
The applicable subheading for the rubber component for both the hydraulic and elastomeric bushing, when made of synthetic rubber (EPDM, NR or BR), will be 4016.99.6050, HTSUS, which provides for other articles of vulcanized rubber other than hard rubber: other: other: other. The rate of duty will be 2.5 percent ad valorem.
The applicable subheading for the glycol mixture will be 2905.31.0000, HTSUS, which provides for Ethylene glycol (Ethanediol). The rate of duty will be 5.5 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 classification of the hydraulic bushing, contact National Import Specialist Kenneth T. Brock at (646) 733-3009. If you have any questions regarding the classification of the elastomeric bushing, please contact National Import Specialist Joan Mazzola at (646) 733-3023. If you have any questions concerning the classification of the glycol mixture, please contact National Import Specialist Stephanie Joseph at (646) 733-3268.
Sincerely,
Robert B. Swierupski
Director National Commodity Specialist Division