CLA-2-90:RR:NC:MM:114 G82747

Ms. Ikue Stoehr
Toyota Motor Sales, U.S.A., Inc.
19001 South Western Avenue
P.O. Box 2991
Torrance, CA 90509-2991

RE: The tariff classification of components for an adaptive cruise control for a vehicle

Dear Ms. Stoehr:

In your letter dated September 19, 2000 you requested a tariff classification ruling.

The adaptive cruise control consists of various components. You are requesting a tariff classification ruling on two of the components of the adaptive cruise control: the laser radar sensor and the distance control electronic control unit.

The adaptive cruise control system maintains a vehicle at a fixed speed set by the driver as long as there are no vehicles ahead in the same lane. If the system detects a vehicle ahead driven at a slower speed, it closes the throttle valve to decelerate the vehicle. If additional deceleration is necessary, it downshifts to decelerate. If further deceleration is necessary, the system controls the brake actuator in order to apply the brakes. The system will then maintain the vehicle distance that is set. If there are no vehicles ahead within the set vehicle-to-vehicle distance, the system accelerates slowly to reach and maintain the set vehicle speed.

The laser radar sensor portion of the adaptive cruise control system, part no. 88210-50030, consists of a laser diode, a collecting lens, a hexagonal mirror, and a photodiode. The laser radar sensor emits a laser beam and uses the reflected beam to detect the presence of a vehicle being driven ahead and to determine the vehicle to vehicle distance. Based on that information, it calculates the relative speed of the vehicle in front. It then transmits that information to the distance control electronic control unit. The laser radar sensor does not react to non-moving objects.

The distance control electronic control unit (DCECU), part no. 88240-50110, has two main continuous inputs (from sensors which will not be in the shipment), i.e., an input of the measurement of the speed of the vehicle and an input of the measurement of the exact distance between the front of the vehicle and the vehicle (if any) ahead of it in its lane.

From time to time, the driver sets the desired speed and distance (long, middle or short). The system automatically disengages when the vehicle is traveling under 28 miles per hour, presumably in non-highway driving.

When there is no vehicle in the lane ahead, the DCECU calculates and issues the instructions to the Engine Control Module (ECM) to give instructions to accelerate, decelerate, shift, brake or make no change as needed to maintain the desired speed.

When there is a vehicle ahead, the DCECU will similarly issue instructions to the ECM to cause the distance interval to maintain the desired standard.

The DCECU automatically changes between the two modes as the lane ahead fills and empties.

The DCECU will also send out display diagnostics and engage a warning buzzer under some circumstances. These functions are clearly subsidiary to its primary function as the “brain” which analyzes the measurement data input, compares it to the desired values, and issues the electronic instructions necessary to maintain two chosen quantities, i.e., vehicle speed and distance, at the desired value

The applicable subheading for the laser radar sensor will be 9015.10.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for rangefinders, electrical. The rate of duty will be free.

The applicable subheading for the DCECU will be 9032.89.6085, Harmonized Tariff Schedule of the United States (HTS), which provides for “other” automatic regulating or controlling instruments. The general rate of duty will be 1.7 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 Barbara Kiefer at 212-637-7058.


Robert B. Swierupski
National Commodity
Specialist Division