CLA-2-40:OT:RR:NC:N1:137

Caitlin Forsythe
Nissan North America, Inc.
One Nissan Way
Franklin, Tennessee 37067

RE: The tariff classification of a natural rubber suspension bumper from Japan

Dear Ms. Forsythe:

In your letter dated October 15, 2021 you requested a tariff classification ruling.

Part number 552404KH4A is described as a suspension jounce bumper. The jounce bumper is composed of natural rubber attached to a steel mounting bracket. It is fitted in motor vehicle chassis, above the suspension leaf spring, in order to absorb the sudden shock imparted as the vehicle travels over potholes, curves and bumps in the road. It also prevents the metal-to-metal contact between the chassis and suspension leaf spring to avoid damage to the metal parts.

You suggested classification in 4016.99.3550, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of vulcanized rubber other than hard rubber: of natural rubber: other: other. We disagree. The primary function of this article is to absorb the shock caused by a vehicle traveling over bumps in the road and prevent metal-to-metal contact. This type of shock absorption is a type of vibration control.

The applicable subheading for the natural rubber suspension bumper will be 4016.99.3000, HTSUS, which provides for other articles of vulcanized rubber other than hard rubber: of natural rubber: vibration control goods of a kind used in the vehicles of headings 8701 through 8705. The general 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 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 Christina Allen at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division