Stuart South, Logistics and Warehouse Manager
Lang-Mekra, North America
101 Tillessen Boulevard
Ridgeway, SC 29130-9424

RE: The tariff classification of a rear-view mirror backing with marker light

Dear Mr. South,

In the letter from your office dated August 25, 2014, you requested a tariff classification ruling. As per your request, the sample which you provided to this office will be returned to your attention.

The item under consideration has been identified as a Mirror Back Cover Kit (Part # 614010003-PDC). The kit contains two (2) stainless steel washer locks, two (2) stainless steel nut hexes, (2) two screws, one (1) marker light with cable connector and bulb and one (1) Chrome Back Cover. You state in your request that the Kit is intended to be used as a replacement to a damaged or loose back cover of rear view mirrors on trucks and buses. The back cover is used to protect the mechanisms, cables and glass within the mirror system. In its imported condition, the Back Cover contains two (2) cables where the marker light is connected to the truck or bus. The marker light is intended to increase the vehicles visibility to other drivers and/or pedestrians.

The applicable classification subheading for the Mirror Back Cover Kit (Part # 61401003-PDC) will be 8512.20.4040, (HTSUS), which provides for “Electrical lighting or signaling equipment … , of a kind used for … motor vehicles … : Other lighting or visual signaling equipment: Visual Signaling Equipment … For the vehicles of subheading 8701.20 or heading 8702, 8703, 8704, 8705 or 8711.”

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

If you have any questions regarding the ruling, please contact National Import Specialist Matthew Sullivan at


Gwenn Klein Kirschner
National Commodity Specialist Division