CLA-2-39:RR:NC:SP:221 F82641
Mr. Mitchell Neriah
Customs Consulting Services
415 S. Prospect Avenue, Suite 110
Redondo Beach, CA 90277
RE: The tariff classification of rubber sealing strips and mounting cushions from Japan.
Dear Mr. Neriah:
In your letter dated January 31, 2000, on behalf of Calhac, Inc., you requested a tariff classification ruling.
Samples of three sealing strips and one mounting cushion were submitted with your request. The strips and cushion will be assembled with other parts in the United States to make a complete electric storage battery for use in a motor vehicle. Part No. 1J506-PHM-000, Part No. 1J507-PHM-000, and Part No. 1J508-PHM-000 are rectangular strips of cellular, vulcanized EPDM rubber with a self-adhesive backing, measuring approximately 3/16 inch in width and 3 to
5 1/2 inches in length. These strips are affixed to a steel plate that fits onto an air duct on the battery and function to prevent outside air leakage into the duct from the area where the duct is joined to the battery case.
Part 1J821-PHM-000 is a vulcanized, non-cellular EPDM rubber spool-shaped fan mount measuring approximately 7/16 inch in outside diameter and 5/16 inch in height. The mount is used as an anti-vibration cushion for attaching an electric fan to one of the ducts on the battery. The samples are being returned as you requested.
You suggest classification of the sealing strips in subheading 4016.10.0000, HTS, which provides for other articles of vulcanized rubber other than hard rubber: of cellular rubber. Even though the seals are ready for use in their imported condition, and are designed and cut to a specific length for exclusive and dedicated use with the air duct plate, they meet the definition of the term strip, and are more specifically provided for as such.
The applicable subheading for the rectangular sealing strips will be 4008.11.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for plates, sheets and strip, of vulcanized rubber other than hard rubber: of cellular rubber, other. The rate of duty will be 3.3 percent ad valorem.
The applicable subheading for the fan mounting cushion will be 4016.99.5500, HTS, which provides for other articles of vulcanized rubber other than hard rubber…other…vibration control goods of a kind used in the vehicles of headings 8701 through 8705. The rate of duty will be 2.5 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 Joan Mazzola at 212-637-7034.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division