Mr. Michael Unsworth
JAS Forwarding (USA), Inc.
35790 Northline Rd., Suite B
Romulus, MI 48174

RE: The tariff classification of rubber bump pads, rear window washer grommets and sealing plugs from China

Dear Mr. Unsworth:

In your letter dated August 28, 2012, on behalf of Zhongli North America, you requested a tariff classification ruling.

The three samples provided with your letter are all composed of ethylene propylene diene monomer (EPDM) synthetic rubber and will be used in automobiles. Article number 68073505AA, described as a bump pad, is a circular bumper designed to prevent the brake components from hitting the front rail. Article number 68073992AA, described as a rear window washer, is a circular grommet designed as an anti-wear component to keep the surrounding metal from cutting through the washer fluid hose. Article number 68086795AA, described as an oval sealing plug, is a solid oval plug used on a floor pan to prevent water leaks. As you requested, the samples will be returned.

You suggest classification of all three styles in subheading 4016.99.6050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of vulcanized rubber, other. Although we agree with this classification for two of the products, the sealing plug is more specifically provided for in a previous subheading of the tariff.

The applicable subheading for article number 68086795AA, the floor pan sealing plug, will be 4016.99.1500, HTSUS, which provides for other articles of vulcanized rubber other than hard rubber: other: caps, lids, seals, stoppers and other closures. The rate of duty will be 2.7 percent ad valorem.

The applicable subheading for article number 68073505AA, the bump pad, and article number 68073992AA, the rear window washer grommet, will be 4016.99.6050, HTSUS, which provides for other articles of vulcanized rubber other than hard rubber, other. The rate of duty will be 2.5 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 Joan Mazzola at (646) 733-3023.


Thomas J. Russo
National Commodity Specialist Division