CLA-2-85:OT:RR:NC:N4:108

Lige Hundley
Senior Sales Engineer
Yokowo Manufacturing of America, LLC
4081 Leap Road
Hilliard, Ohio 43026

RE: The tariff classification of antennas from China

Dear Mr. Hundley:

In your letter dated December 2, 2016, you requested a tariff classification ruling.

The merchandise under consideration is the OEM Antennas which will be installed on automobiles.  There are three variations in question.  Variation #1 consists of an antenna for a GPS and an antenna for a SXM (Satellite Radio).  The GPS antenna is used for the GPS navigation system.  The SXM (Satellite Radio) antenna is used with the SXM radio broadcast receiver.  Variation #2 consists of an antenna for a GPS1 (Navi), an antenna for a GPS2 (TEL), an antenna for a SXM (Satellite Radio), and an antenna for LTE (TEL).  The GPS1 antenna is used for the GPS navigation system; the GPS2 antenna is used for the telematics transmission/reception; the SXM (satellite) antenna is used with the SXM radio broadcast receiver; and the TEL antenna, which works in conjunction with the GPS2 antenna, is used to send and receive transmission in an accident or emergency.   Variation #3 is an antenna for a GPS.  The GPS antenna is used for the GPS navigation system.  In your submission you suggest classification of all three models in subheading 8529.10.4080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: Parts suitable for use solely or principally with the apparatus of headings 8525 to 8528: Antennas and antenna reflectors of all kinds; parts suitable for use therewith: Radar, radio navigational aid and radio remote control: Other.  However, it is the opinion of this office that in the first two variations no one component imparts the essential character of the composite goods.   As such, for Variations # 1 and # 2 we apply GRI 3(c), and classify the merchandise in subheading 8529.10.91, the subheading occurring last numerically among those subheadings which equally merit consideration.  Regarding Varation #3, we believe that it is more specifically classified as a radio navigational aid antenna.  The applicable subheading for Variation #1 and #2 will be 8529.10.9100, HTSUS, which provides for: Parts suitable for use solely or principally with the apparatus of headings 8525 to 8528: Antennas and antenna reflectors of all kinds; parts suitable for use therewith: Other. The rate of duty will be 2.2%.

The applicable subheading for Variation #3 will be 8529.10.4040, HTSUS, which provides for: Parts suitable for use solely or principally with the apparatus of headings 8525 to 8528: Antennas and antenna reflectors of all kinds; parts suitable for use therewith: Radar, radio navigational aid and remote control: Antennas. 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 https://hts.usitc.gov/current.

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 Lisa Cariello at lisa.a.cariello.cbp.dhs.gov.

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division