CLA-2-85:OT:RR:NC:N2:220
Daniel Cannistra
Crowell and Moring LLP
1001 Pennsylvania Avenue NW
Washington, DC 20004
RE: The tariff classification of Drive Wiper Assemblies from Mexico
Dear Mr. Cannistra:
In your letter dated May 5, 2020, you requested a tariff classification ruling on behalf of your client, Valeo North America Inc.
The merchandise under consideration is identified as Wiper Modules with DC Motor (Wiper Modules). You submitted five Wiper Modules, PN W000077735, PN W000060390, and PN W000050762, which are motor assemblies with a maximum output of 60 W, PN W000076689, which is a motor assembly with a maximum output of 67.3 W, and PN W000079033, which is a motor assembly with a maximum output of 65 W. Each of the Wiper Modules consist of an electric DC motor, the pivot assembly, the shaft assembly, and the grommet assembly. The Wiper Modules are intended to be used in a windshield wiper system for a motor vehicle by transforming the rotational motion of the motor to oscillatory motion for the wipers. We would note that the wiper arms and/or wiper blades are not attached to the subject Wiper Modules at the time of importation.
In your request, you suggest that the Wiper Modules are classifiable under subheading 8501.31.2000, Harmonized Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for the Wiper Modules with DC Motor, PN W000077735, PN W000060390, PN W000050762, PN W000076689, and PN W000079033, will be 8501.31.2000, HTSUS, which provides for “Electric motors…: Other DC motors; DC generators: Of an output not exceeding 750 W: Motors: Exceeding 37.5 W but not exceeding 74.6 W”. The general rate of duty will be 2.8 percent 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 the 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 Karl Moosbrugger at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division