CLA-2-87:OT:RR:NC:N1:101

Ralph Garcia, Manager-International Trade Compliance
Mitsubishi Motors North America, Inc.
6400 Katella Avenue
Cypress, CA 90630-5208

RE: The tariff classification of a nut from Japan.

Dear Mr. Garcia,

In your letter dated September 7, 2011, you requested a tariff classification ruling.

The item under consideration is a Front Wheel Hub Nut (Part # MB160696). You state that it is a disc-shaped component made from steel and measures 72 millimeters in diameter by 9 millimeters in thickness. Its center-threaded hole measures 45 millimeters in diameter and the edge of the Nut measures 13.5 millimeters. You state that the circular Nut is not shaped for torqueing (ie: hex, squared, etc.) On its edge, The Nut has four (4) equidistant holes, two (2) of which are threaded and two (2) without threads. The two (2) threaded holes serve as a mounting surface for the front wheel hub washer. The two (2) unthreaded holes mesh with two (2) pegs protruding from the washer. The Nut’s purpose is to turn and lock the front wheel hub for four (4)-wheel drive operation.

In your request, you propose classification of the Front Wheel Hub Nut (Part # MB160696) in subheading 8708.99.6890 of the Harmonized Tariff Schedule of the United States (HTSUS) which provides for “Parts … of … motor vehicles … : Other parts … : Other: Other: Other: Other: Other parts for power trains: Other.” Wheel Hubs, of which the Front Wheel Hub Nut is a part, are not classified as parts for power trains (see HTSUS subheadings 8708.99.5800 and 8708.99.8115), therefore, as a part of the Wheel Hub Units, the Front Wheel Hub Nut is, also, not classified as a part for power trains.

Classification of goods in the Harmonized Tariff Schedule of the United States (HTSUS) is governed by the General Rules of Interpretation (GRIs). GRI 1. states “ ... classification shall be determined according to the terms of the headings ... .” Heading 8708 provides for “Parts … of … motor vehicles … .”

General Note 3. (h) (vi) to the HTSUS states “ ... a reference to “headings” encompasses subheadings indented thereunder.” Subheading 8708.99.81 provides for “Parts … of … motor vehicles … : Other parts … : Other: Other: Other: Other: Other.”

The applicable classification subheading for the Front Wheel Hub Nut (Part # MB160696) will be 8708.99.8180, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Parts … of … motor vehicles … : Other parts … : Other: Other: Other: Other: Other: Other." The rate of duty will be 2.5%.

Duty rates are provided for your convenience and are subject to change. The text of the most recent Harmonized Tariff Schedule of the United States and the accompanying duty rates are provided on the World Wide Web at http://ww.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 Richard Laman at 646-733-3017.


Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division