CLA-2-87:OT:RR:NC:N2:206
Matthew Wasserbach
Corbett International
133-33 Brookville Blvd, Suite 203-F
Rosedale, NY 11422
RE: The tariff classification and country of origin of a bus door from Turkey
Dear Mr. Wasserbach:
In your letter dated October 5, 2018, you requested a tariff classification ruling on behalf of your client Polyrit in Israel.
The item under consideration has been identified as a Bus Door (Part Number 03-29-2741), which is a side baggage door for buses. Typically, there are 6 such doors to a bus, with 3 on each side. The door is made of polyurethane (PU), and metal (stainless-steel) frame with brass inserts.
The applicable subheading for the Bus Door (Part Number 03-29-2741) will be 8708.29.1500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories of bodies (including cabs): Other: Door assemblies.” The general duty rate will be 2.5% 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 https://hts.usitc.gov/current.
In your letter you also requested a country of origin determination. Section 134.1(b), Customs Regulations (19 CFR 134.1(b)), defines "country of origin" as the country of manufacture, production, or growth of any article of foreign origin entering the U.S. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the "country of origin” within this part. A substantial transformation occurs when articles lose their identity and become articles having a new name, character or use.
You state in your letter that the PU materials for the bus door are imported into Turkey from Germany in raw form. The PU system is then combined with the metal frame and brass inserts, which are made in Turkey. Based on the information provided, it appears that the PU system underwent a substantial transformation in Turkey to become a bus door, taking on a new name, character, and identity. As a result, the country of origin for the bus door will be Turkey.
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 Liana Alvarez at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division