CLA-2-87:OT:RR:NC:N2:206
Stephen Mazzarelli
Commercial Sewing
65 Grant Street Torrington, CT 06790
RE: The tariff classification of UTV Door Cover Skins from China
Dear Mr. Mazzarelli:
In your letter dated January 12, 2023, you requested a tariff classification ruling.
The first item article under review is a set of Sewn Door Cover Skins (Component Part # P75-1149). The skins are attached to the metal door frame of a Utility Terrain Vehicle (UTV). They are constructed of 40% polyester, 5% Polyvinyl Chloride (PVC), 20% Ethylene Propylene Diene Monomer (EPDM) rubber and 5% nylon. The material is a light gray warp knit polyester with a black PVC face side coated and embossed. The clear window is vinyl super double polished, with a 0.030 gauge thick single layer with a cold crack resistance of up to -30 degrees (Fahrenheit). It is cut to a specific shape for a specific vehicle model and is sewn together with a zipper to open the clear window.
The second item under review is a set of Compression Molded Door Skins (Component Parts P75-1109 and P75-1110). They are constructed of 35% Polyvinyl Chloride (PVC), 20% Polyurethane (PU), 20% Ethylene Vinyl Acetate (EVA), 20% Polyester, 3% Polypropylene (PP) and 2% Magnets. The three-layer compression molded skins have Ethylene Vinyl Acetate (EVA) foam with an inside layer of polyester knit tricot and an outside layer of polyurethane film. Both the inside and outside laminated layers are black and the EVA is a closed cell foam and is cellular. The inner layer of knit is 90 g/m2, the middle layer of EVA foam is 240 grams per square meter (g/m2), and the outer layer of polyurethane is 255 g/m2 for a total of 585 g/m2. The three-layered material is compression molded to a specific shape for the specific vehicle model it is designed for. The clear window is a vinyl super double polished clear 0.030 gauge thick single layer with a cold crack resistance of up to -30 degree (Fahrenheit). It is sewn together with a zipper to open the clear window.
The applicable subheading for the UTV Door Cover Skins (Component Part # P75-1149) and the Compression Molded Door Skins (Component Parts P75-1109 and P75-1110) will be 8708.29.1500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of motor vehicles of heading 8701 to 8705: Other parts and accessories of bodies (including cabs): Other: Other: Door assemblies.” The rate of duty will be 2.5% ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8708.29.1500, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8708.29.1500, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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 at https://hts.usitc.gov/current.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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