CLA-2-84:OT:RR:NC:1:102
Lora Mayo-Brown
Robert Bosch LLC
8101 Dorchester Road
Charleston, South Carolina 29418
RE: The tariff classification of Brake Booster Assemblies from Germany.
Dear Ms. Mayo-Brown:
In your letter dated January 23, 2015 you requested a tariff classification ruling.
The products under consideration are described as Bosch Item, iBooster Assembly and Bosch Item, iBooster Assembly without the Tandem Master Cylinder Unit. The Bosch Item, iBooster Assembly is comprised of an EC-Motor, which serves as the power unit that drives a Two Staged Gear unit/assembly. Torque generated from the EC-Motor is transmitted through the Two Staged Gear unit/assembly to the Driver Demand Unit (DDU), which incorporates a Push Rod that ultimately actuates the Tandem Master Cylinder (TMC).
The iBooster Assembly also incorporates a vehicle interface to connect the iBooster Assembly to the vehicle firewall, a pedal coupling unit to couple the iBooster Assembly with the vehicle pedal unit, and a pedal travel sensor to detect the driver brake request. The TMC is comprised of the following components: a machined aluminum body, a cover, pistons, seals and a reservoir that holds the brake fluid. The primary function of the TMC is to generate hydraulic pressure, via pumping brake fluid. When the brake pedal is depressed, the EC-Motor drives the Gear Unit/Assembly that ultimately transmits linear power to a plunger, which then is used to drive the primary and secondary pistons within the TMC, therefore pumping/forcing brake fluid, stored in the reservoir, into the brake lines to actuate the vehicle’s brakes.
It is said, the iBooster is an electromechanical brake booster that is designed to replace a vacuum power booster and the vacuum supply. The iBooster amplifies the drivers input force. It takes the drivers applied brake demand and through the use of an electronic control device (ECU), the unit electromechanically transforms the driver’s applied brake demand into amplified brake pressure, similar to the effects of a conventional vacuum power brake booster. It is also said, the iBooster is designed to be used with hybrids and electric vehicles.
The primary function of the iBooster Assembly when imported together with the TMC is to transmit/force brake fluid to the brakes. Pumps or machines that displace liquid are specifically provided for under Heading 8413, Harmonized Tariff Schedule of the United States (HTSUS). Based on this item’s functionality, the applicable subheading for the Bosch Item, iBooster Assembly will be 8413.50.0080, HTSUS, which provides for other reciprocating positive displacement pumps for hydraulic fluid. The rate of duty will be free.
This office finds that the iBooster Assembly, when imported without the TMC, is identifiable as a part of a pump in HTSUS heading 8413. The information submitted states this electromechanical mechanism is incorporated into a type of pump machine (i.e. Brake Booster, iBooster Assembly with the TMC) and is an integral part of the mechanism used to create hydraulic pressure needed to push brake fluid through the brake lines in order to stop the vehicle. As such, the applicable subheading for the iBooster without the TMC will be 8413.91.9050, HTSUS, which provides for parts of Hydraulic Fluid Power Pumps. 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, contact National Import Specialist Sandra Martinez at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division