Rehau Automotive LLC
1501 Edwards Ferry Rd
Leesburg, VA 20176
RE: The tariff classification of ultrasonic sensors from Germany
Dear Ms. Ingels:
In your letter dated May 29, 2019, you requested a tariff classification ruling.
The merchandise under consideration is described as an ultrasonic sensor to be used for maneuvering and parking assistance within a vehicle. The item consists of a capacitive transducer, which is intended to be mounted to the underside of either the rear or side bumper of a vehicle. You state that the sensor works on a pulse-echo principle by transmitting short ultrasonic impulses that are reflected by surrounding objects back to the sensor for detection. If an object is detected as being too close to the vehicle, the sensor sends an electronic pulse through the vehicle's ECU to notify the driver. You state that the sensors improve the driver's experience by simplifying parking and maneuvering of the vehicle.
In your request you suggest that the ultrasonic sensor should be classified under subheading 8512.90.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Electrical lighting or signaling equipment (excluding articles of heading 8539), windshield wipers, defrosters and demisters, of a kind used for cycles or motor vehicles; parts thereof: Parts: Other." We disagree.
While heading 8512 provides for visual and signaling equipment used in motor vehicles, it does not provide for parts that are specifically provided for elsewhere. Though the items under consideration will, in fact, eventually be incorporated into a system that may be used in a motor vehicle, the units by themselves incorporate a capacitive transducer that is more specifically provided for in Chapter 85. Therefore, classification under heading 8512 is precluded.
The applicable subheading for the ultrasonic 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; parts thereof: Other machines and apparatus: Electric syncros and transducers; flight data recorders; defrosters and demisters with electric resistors for aircraft: Other." The general rate of duty will be 0.6% as 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 the 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 Luke LePage at firstname.lastname@example.org.
Steven A. Mack
National Commodity Specialist Division