Ms. Marilee Rice
Kuehne and Nagel
12000 E47th Avenue
Denver, Colorado 80239
RE: The tariff classification of Automotive Electronic Distributor Modules from Poland.
Dear Ms. Rice:
In your letter dated March 7, 2006 you requested a tariff classification ruling on behalf of your client Woodward Governor Company.
The item is an automotive Electronic Distributor Module (EDM-HD). It is an ignition coil driver that takes firing commands from an engine controller and drives ignition coils. The engine control module reads a current monitor “Imon” feedback signal from the EDM-HD. The Imon feedback signal allows the control modules to perform diagnostics on the EDM-HD and also allows the control modules to adjust the Trigger pulse timing to minimize the ignition coil current draw and consequent self-heating of the EDM-HD semiconductor switches and the ignition coils.
The EDM-HD sends signals out the ignition coils to cause them to spark and ignite at the proper time.
The applicable subheading for the Automotive Electronic Distributor Modules will be 8511.30.0040, Harmonized Tariff Schedule of the United States (HTSUS), 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. The rate of duty will be 2.5 percent.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.
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