CLA-2-84:RR:NC:4:102 A84656
Mr. William J. Phelan
One Atlantic Street
Stamford, CT 06901
RE: The tariff classification of a replacement automotive clutch kit from Japan
Dear Mr. Phelan:
In your letter dated June 11, 1996, on behalf of your client, Subaru of America, you
requested a tariff classification ruling.
The item at issue here is a replacement clutch kit, part number X3011AA340, for
automotive use. The kit consists of four components: a clutch disk, clutch cover (clutch plate),
clutch release bearing, and a pilot bearing. It is our opinion that the four components constitute an
entire clutch assembly rather than a kit. As such they would remain classified under one heading
rather than being classifiable as individual components. Clutch assemblies, while specifically
provided for in heading 8483, if solely or principally used for automotive applications, are
excluded from that provision by the headnotes to Section XVI of the HTS. In addition, we do not
consider the clutch assembly to be a functional part of the automobile engine.
The applicable subheading for the clutch kit will be 8708.93.6000, Harmonized Tariff
Schedule of the United States (HTS), which provides for parts and accessories for motor vehicles;
clutches, for other vehicles. The rate of duty will be 2.9 percent ad valorem.
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 J. Riedl at 212-466-5493.
Sincerely,
Roger J. Silvestri
Director
National Commodity Specialist Division