Mr. Ee-Shin Chang
American Honda Motor Co., Inc.
1919 Torrance Boulevard
Torrance, California 90501-2746
RE: The tariff classification of automotive Turn Signaling Equipment Housing with Lenses from Japan
Dear Mr. Chang:
In your letter dated December 15, 1999 you requested a tariff classification ruling.
You submitted diagrams from your electronic parts catalog illustrating the parts in question. They include five different parts that are used in a passenger vehicle. The front lamp units, part number 33301-ST7-A11 and 33301-SR2-A02, are front turn signal lights. Part number 33501-SH2-A02, 33351-SB6-671, and 33551-S04-Q51 are taillights. All five parts are turn signaling equipment housings with lenses that do not include bulbs, sockets, wires or gaskets.
Your position is that the housing/lens bears the essential character of a lighting or signaling equipment instead of parts of a lighting or signaling equipment. You further state that without the bulbs, sockets, wires, and gaskets, the turn signaling equipment housing a reflective lens represent from 91% to 79% of the total value and weight of a "complete signaling equipment" and therefore possess the essential character of a complete lighting or signaling equipment. Value is only one consideration in determining "essential character."
The applicable subheading for the Turn Signaling Equipment Housing with Lenses will be 8512.90.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for Electrical lighting and signaling equipment (excluding articles of heading 8539), windshield wipers, defrosters and demisters, of a kind used for cycles or motor vehicles; parts thereof: Parts: Of signaling equipment. The rate of duty will be 2.5% 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 212-637-7035.
Robert B. Swierupski