CLA-2-85:OT:RR:E:NC:N1:109
Ms. Jennifer L. Ryan
Customs Compliance Analyst
HL-A Co., Inc.
902 Ravenwood Drive
Selma, AL 36701
RE: The tariff classification of a Smart Handle Assembly from Japan
Dear Ms. Ryan:
In your letter dated November 6, 2008 you requested a tariff classification ruling.
The merchandise subject to this ruling is a Smart Handle Assembly, which you refer to as component part number TK4-51S00-3400. The part is a partial automobile door handle fitted with electrical components. The imported part consists of a plastic handle casing with a plastic button. Inside the plastic casing the working parts are; a populated PCB (Power Circuit Board) with EPROM (Erasable Programmable Read Only Memory) and a switch combined, a resistor, an insulated wiring harness with a coupler on the end, a sensor under the button and an LF (low frequency) antenna.
You state in its imported condition that the assembly cannot function singularly as a door handle, but can function as a switch assembly if connected to a power source. The electrical function relies on a capacitive touch sensor to trigger the Smart Entry System to search for the frequency operated button (fob). An LF antenna receives the fob signal and relays that information to the Smart Entry ECU (Electronic Control Unit) to determine if the locks should be opened. As such, this apparatus performs a reception/transmission function within an automobile’s networking system.
The applicable subheading for the Smart Handle Assembly will be 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other." The rate of duty will be free.
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 Linda M. Hackett at (646) 733-3015.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division