Mr. Jeremy Ross Page
Sandler, Travis & Rosenberg, P.A.
225 W. Washington Street
Suite 1550
Chicago, IL 60606

RE: The tariff classification of plastic climate control panel cover plates from an unspecified country.

Dear Mr. Page:

In your letter dated July 9, 2008, you requested a tariff classification ruling on behalf of your client, DENSO Manufacturing Tennessee, Inc.

Under consideration are molded plastic control panel cover plates for automotive heating/air conditioning systems. Climate control panels with integrated switches are affixed to the dashboards of motor vehicles; these cover plates are specifically designed to be placed over the control panels. The cover plates feature cut-outs for the various switches of the control panel that will be used to adjust the car’s climate control system, while molded plastic knobs placed over the switches allow the user to more easily grip the switch and adjust the settings. Each cut-out is clearly labeled with the function of that particular switch. As imported, the cover plates do not contain any electrical components.

In your ruling request you propose classification of these items in 9032.90.6080, Harmonized Tariff Schedule of the United States (HTSUS) as parts of automatic regulating or controlling instruments and apparatus. However, your import does not meet the definition in Note 7 to Chapter 90, HTSUS. It is apparently used as part of a larger control which does not “only” give the instructions to bring a measured factor to a desired value and automatically maintain it there, stabilized against disturbances, but which also provides for manual control by the user of venting options, etc. In Headquarters Ruling Letter H004652, 10-10-07, and H008629, 8-13-07, and New York Ruling Letter K86986, 7-15-04, which you cite, those imports were used only in maintaining the temperature of the seat, etc., at the chosen setting. Alternatively, you suggest classification of the control panel covers in 8415.90.8045, HTSUS, as parts of air conditioning machines, but similar articles, such as those described in New York Rulings F84252 and F84456, have not been found to be classified in 8415, HTSUS. The applicable subheading for the air conditioning panel will be 8538.90.6000, HTSUS, which provides for “Parts suitable for use solely or principally with the apparatus of heading 8535, 8536, or 8537: Other: Other: Molded parts.” The general rate of duty will be 3.5 percent ad valorem.

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

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 Thomas Campanelli at 646-733-3016.


Robert B. Swierupski
National Commodity Specialist Division