CLA-2-85:RR:NC:N1:113 D84978

Mr. Robert J. Resetar
Porsche Cars North America, Inc.
980 Hammond Drive
Suite 1000
Atlanta, GA 30328

RE: The tariff classification of seat heating elements from Germany

Dear Mr. Resetar:

In your letter dated November 18, 1998, you requested a tariff classification ruling.

The merchandise is an electric heating element used in the seat of an automobile. The item is made of an electrical heating element wire sandwiched between two layers of heat resistant plastic. At the end of the wires is an electrical plug that is to be attached to a wiring harness. The element will be placed between the seat cover and the seat cushion. A separate switch on the center console will adjust the heat. The applicable subheading for the seat heating element will be 8516.80.8000, Harmonized Tariff Schedule of the United States (HTS), which provides for electrical heating resistors, other. The rate of duty will be 0.8 percent ad valorem. The rate of duty beginning January 1, 1999 will be free.

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 James Smyth at 212-466-2084.


Robert B. Swierupski
National Commodity
Specialist Division