Robert Bosch LLC
8101 Dorchester Road
North Charleston, SC 29418
RE: The tariff classification of wheel speed sensors from Germany, Japan, and Mexico
Dear Ms. Brown:
In your letter dated November 21, 2016, you requested a tariff classification ruling.
The merchandise at issue is identified as a Bosch wheel speed sensor. The sensor is used to measure the rotational speed of an automotive vehicle’s wheels. The sensor operates on the principal of the Hall Effect, wherein a sensing element is exposed to the magnetic field of a rotating encoder. The sensor converts the change in the magnetic field resulting from the wheel’s rotation into a digital pulse signal and transmits it to appropriate electronic control unit (ECU) in the vehicle (such as the anti-lock braking system unit). The electronic control module interprets the signal received from the sensor and, based on the frequency of the pulses, determines the wheel speed accordingly.
You suggest classification of the wheel speed sensors at issue in subheading 9031.80.8085, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “other” measuring and checking instruments. You indicate that the sensors covered by your submission do not merely send a signal that conveys information on the rotation speed of the wheel to a ECU, rather the signal also includes data that enables the ECU to determine additional information, such as the direction of rotation and the position of the wheel. While the ECU may be able to glean this information from the signal sent by the sensor, it does not appear that the sensor itself performs any measurements. The necessary computations to obtain a measurement of wheel speed and other variables are conducted by the ECU to which the sensor sends its data. The sensor primarily converts the change in magnetic field caused by the wheel’s rotation into a signal that can be interpreted by the ECU. In this respect the wheel speed sensors covered by your submission largely function in the same manner as those addressed in New York Ruling Letter N216101, dated May 17, 2012. Consequently, the wheel speed sensors would not be classified in heading 9031.
The applicable subheading for the Bosch wheel speed sensors will be 8543.70.4500, HTSUS, which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter…: Other machines and apparatus: Electric synchros and transducers…: Other.” The rate of duty will be 2.6% 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 https://hts.usitc.gov/current.
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 Steven Pollichino at Steven.Pollichino@cbp.dhs.gov.
Steven A. Mack
National Commodity Specialist Division