Ms. Carol Roberts, Customs Specialist
New Sabina Industries, Inc.
12555 U.S. Highway 22 & 3
Sabina, OH 45169-9463

RE: The tariff classification of automotive signaling equipment from Mexico

Dear Ms. Roberts,

In your letter dated July 1, 2011, you requested a tariff classification ruling.

The item under consideration has been identified as the Reflected LED Alert Display (RLAD) (Part number GM0029001). You state that the RLAD is a display device which is attached by screws to the instrument cluster of an automobile which is then mounted to the vehicle. The RLAD is only a display and makes no decisions regarding when to illuminate a warning. The instrument cluster activates the RLAD when the vehicle senses that the driver is too close to a vehicle or object in front of it, projecting a virtual image of six (6) red circles onto the windshield. The LED circles will have a day and night time intensity level based on control logic from the cluster and are spaced horizontally at 8 mm intervals; each no less than 5 mm in diameter. The circles warn the driver that corrective action or adjustments need to be taken to avoid a dangerous situation. The LED lenses are optical lenses made of polycarbonate. They will be placed above the LED to help focus the light to achieve image roundness and brightness as specified by each automobile manufacturer.

You propose in your request that the Reflected LED Alert Display (RLAD) (Part # GM0029001) be classified in Harmonized Tariff Schedule of the United States (HTSUS) subheading 8531.20.0040 which provides for “Electric … visual signaling apparatus … other than those of heading 8512 [emphasis added] … : … light emitting diodes: Other.”

Classification of goods in the Harmonized Tariff Schedule of the United States (HTSUS) is governed by the General Rules of Interpretation (GRIs). GRI 1. states “ ... classification shall be determined according to the terms of the headings ... .” Heading 8512 provides for “Electrical … signaling equipment … of a kind used for … motor vehicles [emphasis added].”

General Note 3. (h) (vi) to the HTSUS states “ ... a reference to ‘headings’ encompasses subheadings indented thereunder.” Subheading 8512.20.40 provides for “Visual signaling equipment.”

The applicable classification subheading for the Reflected LED Alert Display (RLAD) (Part # GM0029001) will be 8512.20.4040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical … signaling equipment … , of a kind used for … motor vehicles … : Other … visual signaling equipment: Visual signaling equipment: For [motor vehicles].” The rate of duty will be 2.5%.

Duty rates are provided for your convenience and are subject to change. The text of the most recent Harmonized Tariff Schedule of the United States and the accompanying duty rates are provided on the World Wide Web at /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 Richard Laman at 646-733-3017.


Robert B. Swierupski
National Commodity Specialist Division