CLA-2-85:RR:NC:MM:101 C86412

Mr. George R. Tuttle Sr.
Law Offices of George R. Tuttle
Three Embarcadero Center, Suite 1160
San Francisco, CA 94111

RE: The tariff classification of automotive ignition immobilizer modules from Germany.

Dear Mr. Tuttle:

In your letter dated April 07, 1998, you requested a tariff classification ruling on behalf of your client Temic Telefunken Microelectronics GmbH of Nurnberg, Germany.

The item is part of an Immobilizer System. The Immobilizer System, of which the Immobilizer Module is a component, is permanently incorporated, at the time of manufacture, into a motor vehicle's ignition starting system for the purpose of restricting access to the vehicle's engine starting process for the prevention of theft.

The Immobilizer Module's only function is to accept a specific electronic coded signal emitted by a transponder within the ignition key, and to emit a signal to the Engine Management Module to perform the function of engine ignition. After the engine starts, the immobilizer performs no operative function. Hence, no continuous or periodic automatic regulation or control is performed by the module.

The Immobilizer Module consists of a printed circuit board on which are mounted a microprocessor with transistors, resistors, and other devices. The ignition key contains the transponder chip, which stores identifier codes and the code word. The Module is accessed only when the key incorporating the transponder is inserted into the ignition.

The applicable subheading for the Immobilizer will be , 8511.90.6040 Harmonized Tariff Schedule of the United States (HTS), which provides for Electrical ignition or starting equipment of a kind used for spark-ignition or compression-ignition internal combustion, other parts, other.. The rate of duty will be 2.6 percent ad valorem.

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 Robert DeSoucey at 212-466-5667.


Robert Swierupski

National Commodity
Specialist Division