CLA-2-84:OT:RR:NC:N1:106

Robert Scott
Williams Controls, Inc.
14100 SW 72nd Avenue
Portland, OR 97224-8009

RE: The tariff classification of a Pedal Assembly from an unspecified country

Dear Mr. Scott:

In your letter dated January 16, 2014, you requested a tariff classification ruling.

The item under consideration has been identified as an Electronic Suspended Pedal Assembly (Part Number WCS-400958). The Electronic Suspended Pedal Assembly consists of a brake pedal and a governor decelerator pedal designed for use in track-type tractors (crawler dozers), you state in your request that this part is specifically designed for models D6-D11 Caterpillar TTT Series crawlers.

The dual pedal assembly includes a brake pedal and a governor decelerator pedal housed in the same enclosure. It is mounted on the firewall inside the cab of the vehicle. Each pedal uses a solid state rotary position sensor to provide a pulse width modulated electrical signal proportional to the angular displacement of the governor decelerator and the brake. This signal is sent via wire harnesses to the vehicle’s ECU (Electronic Control Unit). Pressing the brake pedal applies braking ability at the wheels while the governor decelerator pedal reduces engine power by limiting the hydrostatic drive output. The governor decelerator is used to modulate the speed of the vehicle as the throttle RPM speed is typically set on the console.

You state the housing of the pedal assembly is made of steel, weighs twenty-five pounds and measures 11 inches in length by 6.5 inches in width by 13 inches in height.

The applicable subheading for the Electronic Suspended Pedal Assembly will be 8431.49.9085, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts suitable for use solely or principally with the machinery of headings 8425 to 8430: Of machinery of heading 8426, 8429 or 8430: Other: Other: Other: Other: Other”. The rate of duty will be Free.

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, please contact National Import Specialist Matthew Sullivan at (646) 733-3013.

Sincerely,

Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division