Mr. Steven B. von Dobschutz
Sound Off, Inc.
P.O. Box 206
5132 37th Ave.
Hudsonville, MI 49426
RE: The tariff classification of automotive lighting equipment from China and Taiwan.
Dear Mr. Von Dobschutz:
In your letter dated September 4, 2004 you requested a tariff classification ruling.
The first item is (your number 002BRKWA3) a Predator Windshield mounting kit. This is a kit you purchase from China, boxed as you have shipped it. The kit is intended for attachment to vehicle warning lights (e.g. police or fire lights), and then used to attach the light to the interior of the windshield of the vehicle. You add three suction cups, three washers, and three screws to the box, and then label it and include it with the vehicle warning light. The unit comes packed in a master carton of 42 pieces which includes a label stating “Made in China.”
The second item is (your number 002FLED) a Predator LED Module reflector. This unit is an optical reflector, used with Light Emitting Diodes. You purchase this reflector from China in master cartons labeled with “Made in China.” And then use it in your manufacturing facility. You add the reflector to a circuit board assembly and cover it with a lens to ma a so-called “light engine” for your Predator series of vehicle warning lights.
The third item is (your number 002HGSM001) a Surface mount housing. This housing is purchased from Taiwan in cartons labeled “Made in Taiwan.” The unit is a die cast aluminum alloy housing which you use for a surface ;mount vehicle warning light. You add a driver circuit board, a light engine, and outer lens to the housing in your manufacturing facility, and then sell the finished good domestically and overseas.
The fourth item (your number PPRH1BKT) is a Permanent mount headliner bracket. You purchase this item domestically. Since it is not imported and you have not indicated any country of origin we are unable to provide classification or marking advice.
The fifth item (your number PPRPSBKT) is a Prisoner Screen mounting bracket. You purchase various individual components for this bracket from domestic sources, while nuts, bolts, and washers come from mixed origin. You package the brackets together in one box and label the box as you have submitted by sample. Since the good is not imported and you have not indicated any country of origin we are unable to provide classification or marking advice.
The applicable subheading for the Windshield mounting kit will be 3926.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for Other articles of plastic and articles of other materials of headings 3901 to 3914; Fittings for furniture, coachwork or the like; Other. The rate of duty will be 5.3 percent.
The applicable subheading for the LED Module reflector will be 8512.90.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for Electrical lighting or signaling equipment (excluding articles of heading 8539), windshield wipers, defrosters and demisters, of a kind used for cycles or motor vehicles; parts thereof; Parts; of signaling equipment. The rate of duty will be 2.5 percent.
The applicable subheading for the Predator Surface mount housing will be 8302.30.3060, Harmonized Tariff Schedule of the United States (HTS), which provides for Base metal mountings, fittings, and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like; base metal hat racks, hat-pegs, brackets and similar fixtures; castors with mountings of base metal; and base metal parts thereof; Other mountings , fittings and similar articles suitable for motor vehicles; and parts thereof; Of iron or steel; of aluminum or zinc; Other . The rate of duty will be 2 percent.
The marking you have indicated in these three articles is correct.
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 646-733-3008.
Robert B. Swierupski