CLA-2-87:OT:RR:NC:N1:106

Young-bin Oh
Hyundai Motor Company
231, Yangjae 2-dong
Seocho-gu, Seoul ASI/KR/KS013
South Korea

RE: The tariff classification of a water hose, pipe and hose assembly, hose assembly (clutch), and hose assembly (rear brakes) from South Korea.

Dear Mr. Oh:

In your letter dated July 03, 2015, you requested a tariff classification ruling.

The first item under consideration has been identified as a Water Hose-Inlet (Item Code 258515W000) which is an assembly of a pipe, brackets, hose and a clamp. The Water Hose-Inlet is a cooling water pipe which functions as a duct for delivering engine coolant of a motor vehicle. It is mounted between the engine and the heater core of the vehicle. The hose is constructed of silicon rubber, the clamp is constructed of steel, the pipe is constructed of stainless steel (SUS) and the bracket is constructed of steel.

The applicable subheading for the Water Hose-Inlet (Item Code 258414W000) will be 8708.99.8180, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other: Other.” The general rate of duty will be 2.5%.

Item 254702GGA0 is identified as a Pipe and Hose Assembly-Oil Cooler. The assembly consists of lengths of hose fixed to two stainless steel pipes. The hoses are made of ethyl propylene diene monomer (EPDM) rubber reinforced by polyester. A stainless steel bracket and clamps enable the assembly to be mounted between an automobile engine and an oil cooler. The assembly is intended to serve as a duct for the delivery of engine coolant. The Pipe and Hose Assembly-Oil Cooler is a composite good, the essential character of which is imparted by the EPDM rubber hoses.

The applicable subheading for the Pipe and Hose Assembly-Oil Cooler will be 4009.32.0050, HTSUS, which provides for tubes, pipes and hoses, of vulcanized rubber other than hard rubber…reinforced or otherwise combined only with textile materials: with fittings, other. The rate of duty will be 2.5 % ad valorem.

Item 416402M300 is identified as a Hose Assembly-Clutch. The article consists of an EPDM rubber hose with steel fittings on each end. The article is designed to function as a pipe that transfers oil pressure from the clutch to the transmission in an automobile. You suggest classification of the Hose Assembly-Clutch in subheading 4009.32, which covers Tubes, pipes and hoses, of vulcanized rubber…: Reinforced or otherwise combined with only textile materials: With fittings. You do not indicate in your submission if the EPDM rubber hose is reinforced or combined with a textile material. If the rubber hose is not reinforced or combined with other material, subheading 4009.12 would apply instead.

The applicable subheading for the Hose Assembly-Clutch, if reinforced or combined with textile material, will be 4009.32.0050, HTSUS, which provides for tubes, pipes and hoses, of vulcanized rubber other than hard rubber…reinforced or otherwise combined only with textile materials: with fittings, other. The rate of duty will be 2.5 % ad valorem.

The applicable subheading for the Hose Assembly-Clutch, if not reinforced or combined with other materials, will be 4009.12.0050, HTSUS, which provides for tubes, pipes and hoses, of vulcanized rubber other than hard rubber… not reinforced or otherwise combined with other materials: with fittings, other. The rate of duty will be 2.5 % ad valorem.

Item 587371R000 is identified as a Hose Assembly-Rear Brake, Lefthand. The article consists of an EPDM rubber hose reinforced with textile material, with steel fittings on each end. The assembly is designed to be mounted to the wheel cylinder of an automobile, and delivers oil pressure from the vehicle’s brake master cylinder to the brake caliper.

The applicable subheading for the Hose Assembly-Rear Brake, Lefthand will be 4009.32.0020, HTSUS, which provides for tubes, pipes and hoses, of vulcanized rubber other than hard rubber…reinforced or otherwise combined only with textile materials: with fittings, brake hoses for the vehicles of subheading 8701.20 or headings 8702, 8703, 8704, 8705 or 8711. The rate of duty will be 2.5 % 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 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).

If you have any questions regarding the Water Hose-Inlet, please contact National Import Specialist Liana Alvarez at liana.alvarez@cbp.dhs.gov. If you have any questions regarding the Hose Assemblies, please contact National Import Specialist Evan Conceicao at evan.conceicao@cbp.dhs.gov.

Sincerely,

Gwenn Klein Kirschner
Director
National Commodity Specialist Division