Mr. Philip Freeman
Cain Customs Brokers Inc.
P.O Box 10
Progreso, Texas 78579
RE: The tariff classification of a rotor from Mexico
Dear Mr. Freeman:
In your letter dated February 12, 1993, on behalf of Wells
Manufacturing Company, McAllen, Texas, you requested a tariff
You have submitted a sample of the imported product which is
a rotor, part no. 863700129, used inside the distributors of
automobiles. The rotor body will be made of U.S. origin
granulated thermo plastic which will be injection molded in
Mexico. All the other parts (the screw, spring and vane) are of
U.S. origin. The rotor will be assembled in Mexico.
The rotor is used to direct the electricity from the
ignition coil to the spark plugs in certain automobile engines.
The rotor is mounted on the distributor shaft. The spring on the
rotor makes contact with the terminal in the center of the
distributor cap, which comes from the ignition coil. As the
shaft rotates, the rotor closes the circuit with the terminals in
the cap that go to the spark plugs.
The applicable subheading for the rotor, part no. 863700129,
will be 8511.80.6000, Harmonized Tariff Schedule of the United
States (HTS), which provides for other electrical ignition or
starting equipment of a kind used for spark-ignition or
compression-ignition internal combustion engines, other. The
rate of duty will be 3.1 percent ad valorem.
Articles classifiable under subheading 8511.80.6000, HTS,
which are products of Mexico may be entitled to duty free
treatment under the Generalized System of Preferences (GSP) upon
compliance with all applicable regulations.
If the imported article is not eligible for GSP, then note
that subheading 9802.00.80, HTS, provides a partial duty
exemption for articles assembled abroad in whole or in part of
fabricated components, the product of the United States, which
(a) were exported in condition ready for assembly without further
fabrication, (b) have not lost their physical identity in such
articles by change in form, shape, or otherwise, and (c) have not
been advanced in value or improved in condition abroad except by
being assembled and except by operations incidental to the
assembly process such as cleaning, lubricating, and painting.
All three requirements of subheading 9802.00.80, HTS, must
be satisfied before a component may receive a duty allowance. An
article entered under subheading 9802.00.80, HTS, is subject to
duty upon the full value of the imported assembled article less
the cost or value of such U.S. components, upon compliance with
the documentary requirements of section 10.24 of the Customs
Regulations (19 CFR 10.24). If you have any questions regarding
subheading 9802.00.80, HTS, please address your request to U.S.
Customs Service, Office of Regulations and Rulings, 1301
Constitution Ave., N.W., Washington, D.C. 20229-0001.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
Jean F. Maguire
New York Seaport