CLA-2-85:RR:NC:MM:101 G89754

Ms. Michelle Davis
Import Manager
Hellmann Worldwide Logistics, Inc.
7200 Alum Creek Road, Suites M & N
Columbus, Ohio 43217-1349

RE: The tariff classification of an automobile Distributor Housing Assembly from Japan

Dear Ms. Davis:

In your letter dated March 28, 2001 you requested a tariff classification ruling.

You submitted a sample as well as a technical drawing of an automobile Distributor Housing Assembly, identified as PAB DSB Kit, Style # A14104-03. No additional information was provided.

You have suggested that the Distributor Housing Assembly is classified under HTS 8511.30.0040, which provides for Electrical ignition or starting equipment of a kind used for spark-ignition or compression-ignition internal combustion engines (for example, ignition magnetos, magneto-dynamos, ignition coils, spark plugs and glow plugs, starter motors); generators (for example, dynamos, alternators) and cut-outs of a kind used in conjunction with such engines; parts thereof: Distributors; ignition coils…Distributors.

We disagree with your proposed classification because the Distributor Housing Assembly is not a complete Distributor.

The applicable subheading for the automobile Distributor Housing Assembly will be 8511.90.6040, Harmonized Tariff Schedule of the United States (HTS), which provides for Electrical ignition or starting equipment of a kind used for spark-ignition or compression-ignition internal combustion engines (for example, ignition magnetos, magneto-dynamos, ignition coils, spark plugs and glow plugs, starter motors); generators (for example, dynamos, alternators) and cut-outs of a kind used in conjunction with such engines; parts thereof: Parts: Other parts…Other. The rate of duty will be 2.5% 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 Robert DeSoucey at 212-637-7035.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division