Cordova Brokerage International, Inc.
9300 Billy the Kid Street
El Paso, TX 79907
RE: The tariff classification of automotive wiring harnesses from Mexico
Dear Mr. Cordova:
In your letter dated August 26, 2021, you requested a tariff classification ruling on behalf of your client, Sumitomo Wiring Systems, Inc.
There are two items at issue with this request. The first, identified by part numbers 82125-06281 and 82125-TBG030, is described as an automotive wiring harness with a thermistor. These electrical wiring harnesses are composed of various sets of insulated wires, terminals, connectors, plastic covers, spiral tubes, and a thermistor. The wiring harnesses are designed to be installed in the Control Unit of an automobile’s automatic transmission. The function of the first harness is to transmit oil temperature signals to the Engine Control Unit (“ECU”) and to transmit electrical signals to the pressure switches (solenoids) inside the car’s automatic transmission. The second harness works similarly to the first but will sense transmission fluid temperature and transmit the data to the ECU. In addition, the harness will receive power signals (on or off) from the ECU and transmit them to the various solenoid fluid pressure switches that connect to the harness.
The second item, identified by part numbers 680305400d and 680584100C, is described as an automotive wiring harness for a driver monitoring system. The harness consists of multiple insulated electrical wires and coaxial wires bundled together into a wiring set affixed with various connectors and terminals at the ends. The harness is used within a vehicle in order to send both electrical and video signals between a camera and the driver monitoring system. You state that neither the electrical nor the video signals are altered in any way within the subject harness.
Regarding the first item, we note that thermistors imported separately are classified in 8533, Harmonized Tariff Schedule of the United States (HTSUS). However, your item contains important elements such as the wiring, terminals, connectors, plastic covers, and spiral tubes which are not described by that heading. Similar to the item described in ruling N247115 (dated 11/21/13), the thermistor sends back an electrical current which is very closely proportional to the temperature of the fluid temperatures. Therefore, the device has the essential character of a thermometer of heading 9025, HTSUS. In your submission you also suggest the wiring harnesses be classified in 9025.90.0600, HTSUS, which provides for “hydrometers and similar floating instruments, thermometers, pyrometers, barometers, hygrometers and psychrometers, recording or not, and any combination of these instruments; parts and accessories thereof: parts and accessories.” We disagree. In this instance the wiring harness is considered a complete article and is therefore not a part.
The applicable subheading for the automotive wiring harnesses with thermistor, part numbers 82125-06281 and 82125-TBG030, will be 9025.19.8085, HTSUS, which provides for “Hydrometers and similar floating instruments, thermometers, pyrometers, barometers, hygrometers and psychrometers, recording or not, and any combination of these instruments; parts and accessories thereof: Thermometers and pyrometers, not combined with other instruments: Other: Other: Other: Other.” The general rate of duty will be free.
The applicable subheading for the automotive wiring harness, part numbers 680305400d and 680584100C, will be 8544.30.0000, HTSUS, which provides for “Insulated (including enameled or anodized) wire, cable (including coaxial cable) and other insulated electric conductors, whether or not fitted with connectors; optical fiber cables, made up of individually sheathed fibers, whether or not assembled with electric conductors or fitted with connectors: Ignition wiring sets and other wiring sets of a kind used in vehicles, aircraft or ships.” The general rate of duty will be 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 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 [email protected].
Steven A. Mack
National Commodity Specialist Division