CLA-2-85:OT:RR:E:NC:N1:109

Ms. Carmen V. Guillen
Sr. Customs Specialist
Mitsubishi Motors North America, Inc.
6400 Katella Avenue
Cypress, CA 90630

RE: The tariff classification of navigation installation kits from Japan

Dear Ms. Guillen:

In your letter dated May 6, 2009 you requested a tariff classification ruling.

The merchandise subject to this ruling is two types of navigation installation kits. They are identified within your submission as Part Numbers MZ360190EX and MZ360192EX. These installation kits are necessary to properly connect the audio navigation unit in a vehicle. However, the installation kits do not include the audio navigation unit. Each installation kit consists of an instrument center panel for the navigation systems with an attached circuit board and a connector receptor, a big metal bracket assembly, a control unit (CAN box # 8750A090, V12 negative ground), a small metal bracket for the CAN box, a GPS antenna assembly for the navigation system, a harness set with five sets of cords with connections, tapping screws, flange screws, a Rockford fosgate, and instruction manuals in English and French.

The instrument center panel is made of plastic and is used as a face plate for the audio navigation unit. The face plate includes a circuit board with a connector receptor. The instrument center panel does not have a function control, only a switch to display the hazardous light indicator and the passenger air bag indicator when it is off and if someone is on the seat without wearing the seatbelt. The attached connector receptor on the back of the face plate is plugged into an existing plug in the vehicle in order to obtain power for the SRA and airbag indicators.

The big metal bracket assembly is used to hold the audio navigation unit in the vehicle. The small metal bracket is used to attach the control unit in the vehicle.

The CAN (computer area network) box contains a printed circuit board, microcomputer with RAM and ROM, EEPROM memory, a CAN transceiver, and the connector. The function of the CAN box is to receive and transmit information from the navigation unit, audio unit, and air conditioning unit and communicate these functions through the navigation unit. The CAN box does not have a display function, the display will be done through the navigation unit.

The microcomputer with RAM, ROM, EEPROM memory, CAN transceiver and connector are mounted on a printed circuit board. The purpose of the microcomputer within the CAN box is for internal communication, as well as to receive and send information to and from the navigation unit and the attached components. The RAM is a computer that temporarily stores data and the data can be accessed randomly and returned in a constant time. The requested information comes from the navigation unit to the attached components on the navigation unit. When the vehicle is shut down, anything contained in RAM is lost. The ROM is storage media with pre-fabricated data permanently stored in it. The data tells the computer how to load the operating system. The EEPROM is a type of non-volatile memory used to store small amounts of data that must be saved when power is removed. This data is for electronic programmed data for the attached components. The microcomputer temporarily receives and transfers the data in RAM between components and the navigation system. It works with the pre-programmed information in ROM and stores information in the EEPROM. The information from the RAM, ROM, and EEPROM gets transmitted to the microcomputer. The integrated circuit board makes the communication possible between the microcomputer and the RAM, ROM, and EEPROM. The information transmitted to the microcomputer will either be temporarily or permanently stored until deleted or changed.

The CAN transceiver is integrated in the CAN box and its function is to receive and send information. The receiving function adapts signal levels from the bus, to level that the CAN box expects and has protective circuitry that protect the CAN box. The sending function converts the transmit-bit signal received from the CAN box into a signal that is sent onto the bus. The bus is a subsystem that transfers data between microcomputer components inside the microcomputer. The CAN box receives the requested information from the navigation unit and transmits it to the attached components. The CAN box is a pass through device which allows the attached components to be able tom communicate to through the navigation unit. The CAN box stores and receives bit of information from the bus until an entire message is available, usually after the CAN box has triggered an interruption. The CAN box then transmits the message stored in the host-processor to the component in question. The difference between the CAN box and the CAN transceiver is that the CAN box is a vehicle bus standard designed to allow microcontrollers and devices to communicate with each other within a vehicle, without a host computer. The vehicle bus is a specialized internal communications network that interconnects components inside a vehicle. The telecommunications network is a network of telecommunications links and nodes arranged so that messages may be passed from one part of the network to another over multiple links and through various nodes.

The GPS (global positioning system) antenna includes a metal bracket with an attached PGS antenna and an electrical cord with a connector. The metal plate with the GPS antenna will be attached to the back of the dashboard and the other side will be connected to the audio navigation unit. The GPS antenna’s main function is to allow the navigation unit to detect and interface with actual GPS satellites in orbit through GPS signals. The GPS receiver is a separate unit, not included with this installation kit.

The five harnesses with connectors will be connected to the back of the audio navigation unit, to the existing vehicle audio connectors, to the pre-wired navigation, and to the control unit CAN box interface connector.

The principal function of these navigation installation kits is that of a routing system within a motor vehicle to permit the transmission and reception of data between individual control units within a vehicle.

The applicable subheading for the navigation installations kits (MZ360190EX and MZ360192EX) will be 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other”. The rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Linda M. Hackett at (646) 733-3015.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division