CLA-2-83:OT:RR:NC:N1:121
Mr. Ralph Garcia
Mgr. International Trade Compliance
Mitsubishi Motors North America Inc.
6400 Katella Ave.
Cypress, CA 90630
RE: The tariff classification of car door components from Japan
Dear Mr. Garcia:
In your letter dated August 3, 2011, you requested a tariff classification ruling. Photographs were provided with your request.
The merchandise under consideration is “Base, FR Door Outside Handle, LH,” part number 5716A307 and “Base, FR Door Outside Handle, LH,” part number 5716A309, which are designed as service parts for Mitsubishi automobiles.
The “Base, FR Door Outside Handle, LH,” part number 5716A307 is made primarily of molded plastic, mounts inside the door assembly and conforms to the stamped contours of the door panel. Its main purpose is to serve as a mounting surface for the door handle, which is not included. When used on the driver’s door, it also supports the “Door Lock Cylinder” (not included). Additionally, it adds to the strength of the door shell.
“Base, FR Door Outside Handle, LH,” part number 5716A307 includes the following components: a “Base” made of molded plastic; a “Lock Actuator Assembly” consisting of a steel lever and a steel spring; and a steel screw and nut. The “Lock Actuator Assembly” serves to open the door through the “Handle Rod” (not included) and returns the handle and locking mechanism (not included) to their original positions; it does not include an electronic actuator.
“Base, FR Door Outside Handle, LH,” part number 5716A309, is identical in design and function to the “Base, FR Door Outside Handle, LH,” part number 5716A307; however, it also incorporates a “Switch Keyless Operation,” which facilitates the process of unlocking the door. The “Switch Keyless Operation” consists of a push button type switch attached to a six inch long wire harness. The “Switch Keyless Operation” is used on vehicles equipped with a “Smart Keyless Entry System.” In this type of vehicle the driver does not need to hold a key or “Keyless Entry Transmitter” (fob) in hand. The driver can gain entry to and operate the vehicle when the fob is carried in close proximity, such as in a pocket or purse.
The “Switch Keyless Operation” is accessible from the vehicle exterior and is used to lock the vehicle without a key. When the push button of the “Switch Keyless Operation” is pressed, a signal is transmitted to the “Keyless System Control Module,” (not included). The “Keyless System Control Module” detects the signal and transmits a signal to the fob. If the fob is in close proximity, it receives the signal and transmits a signal back to the “Keyless System Control Module,” which in turn triggers the locking mechanism to lock all doors.
You propose classifying both models of the “Base, FR Door Outside Handle, LH” in subheading 3926.30.5000, HTSUS, which provides for plastic fittings for furniture, coachwork or the like. We agree with your proposal for part number 5716A307, however we disagree with your proposal for part number 5716A309.
You indicate that the “Switch Keyless Operation” comprises two thirds of the value of the “Base, FR Door Outside Handle, LH.” part number 5716A309. Additionally, the “Switch Keyless Operation” plays a significant role in the electronic operation of the door locking mechanism. Accordingly, by application of GRI 3(b), the “Switch Keyless Operation” imparts the essential character to the “Base, FR Door Outside Handle, LH,” part number 5716A309.
The applicable subheading for the “Base, FR Door Outside Handle, LH,” part number 5716A307, will be 3926.30.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics and articles of other materials of headings 3901 and 3914, fittings for furniture, coachwork or the like, other. The rate of duty will be 5.3 percent ad valorem.
The applicable subheading for the “Base, FR Door Outside Handle, LH,” part number 5716A309, will be 8301.60.0000, HTSUS, which provides for parts of padlocks and locks (key, combination or electrically operated), of base metal. The rate of duty will be 2.8 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