CLA-2-85:S:N:N1:809651 112
Ms. Christine M. Johnson
Robert Bosch Corporation
P.O. Box 10347
Charleston, SC 29411
RE: The tariff classification of airbag electronic control units
from Mexico
Dear Ms. Johnson:
In your letter dated April 25, 1995 you requested a tariff
classification ruling.
As indicated in your request, the airbag electronic control
unit (AECU) consists of approximately 150 stationary parts, such
as resistors, capacitors, diodes and transistors, which are
assembled onto a printed circuit board and placed in a housing.
The principal hardware of the module consists primarily of an
acceleration sensor, a microcontroller, and output power drivers
for squib firing. This unit performs two basic functions;
analysis of the crash signal and system diagnostics. If an
automobile has a large change of velocity in a relatively short
time, and the instantaneous acceleration of the vehicle is very
large, the system software recognizes that the auto is in a crash
situation. An electric signal is amplified to provide energy to
fire a squib, or triggering unit, which ignites the chemical
process used to generate airbag inflation gas.
In your letter, you express the opinion that the AECU is
properly classified under heading 8537, HTS, since it is a base
for the electric control or distribution of electricity, and
contains two or more of the electrical apparatus functioning as
described in headings 8535 or 8536, HTS. We cannot agree that
heading 8537 applies, since the AECU contains only one apparatus
(plugs) from headings 8535/8536. The fact that other components
may function as electrical apparatus from headings 8535/8536 is
not relevant to this determination.
The applicable tariff provision for the airbag electronic
control unit will be 8543.80.9890, Harmonized Tariff Schedule of
the United States Annotated (HTSUSA), which provides for other
electrical machines and apparatus, having individual functions,
not specified or included elsewhere in this chapter. The general
rate of duty will be 3.6 percent ad valorem.
This ruling is being issued under the provisions of Part 177
of the Customs Regulations (19 CFR 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport
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DEPARTMENT OF THE TREASURY - U.S. CUSTOMS SERVICE CORRESPONDENCE APPROVAL AND CLEARANCE Form 100