CLA-2-73:RR:NC:1:118 G81079
Ms. Kathy Young
DAA Draexlmaier Automotive of America LLC
1751 East Main Street
P.O. Box 1345
Duncan, SC 29334
RE: The tariff classification of metal spring clips from Germany.
Dear Ms. Young:
In your letter dated August 15, 2000, you requested a tariff classification ruling.
You have described your submitted sample, part number M05 00 036, as metal spring clips that hold a module in place after assembly. They are spring loaded to prevent rattling and enable the module to be disassembled after release of the plastic hooks. The spring clips are made of stainless steel. These clips are specifically designed for several BMW models. The clips are attached to the back of carrier plates that are molded at your plant in Duncan, SC. The carrier plates are shipped to BMW with the clips attached to the back. When BMW receives these carrier plates, they are assembled into the automobile. Once they are assembled into the automobiles, modules will be incorporated into the carrier plates.
The applicable subheading for the metal spring clips will be 7320.90.5060, HTS, which provides for springs and leaves for springs, of iron or steel: other: other: other. The general duty rate will be 2.9% ad valorem.
Consideration was given to classifying this product under subheading 7318.29.0000, HTS, as you have suggested. However, as your items act as springs your suggested classification is deemed inappropriate.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of this 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 Kathy Campanelli at 212-637-7025.
Sincerely,
Robert B. Swierupski
Director
National Commodity
Specialist Division