CLA-85:OT:RR:NC:N1:109
Ms. Justine Bacani
Customs Specialist II
Mitsubishi Motors North America, Inc.
6400 Katella Avenue
Cypress, CA 90630
RE: The tariff classification of a USB adapter, a USB cable kit, an audio & video adapter, and a USB cable from Japan
Dear Ms. Bacani:
In your letter dated February 25, 2011 you requested a tariff classification ruling.
The merchandise subject to this ruling is a USB adapter, a USB cable kit, an audio & video adapter, and a USB cable.
The USB adapter is identified within your letter as Part No. 8718A007. It is a standard USB 2.0 connector encased in a plastic housing with a snap-on lid and is positioned in the inside corner of the center console of an automobile. Its connection to the automobile’s wireless communication system via a USB cable enables users to plug in their cell phones, media storage devices, and media players to connect through the vehicle’s audio system. The USB adapter also acts as a power source designed to provide USB direct current (DC) power and to charge the batteries within PDAs, iPods, Blackberries, cellular phones, digital cameras, and most other consumer electronics with USB power ports.
The USB cable kit is identified within your letter as Part No. MZ360331EX. It is an after-market accessory kit for installation into automobiles that do not have a USB adapter built-in so that users can connect their electronic device to the automobile’s wireless communication system, which is connected to the automobiles audio system. The kit consists of a USB adapter, a USB cable, a plastic floor box insert for the center console of an automobile, 3 plastic strap ties and printed installation instructions. The floor box insert has a special fitted compartment to fit the USB adapter and holes for the USB cable to connect to the adapter. It is designed to replace the original box insert on the automobile’s floor console box, which does not allow for the adapter and the cable to be connected.
The audio & video adapter is identified within your letter as Part No. 8718A002. It is a stereo auxiliary output adapter encased in a plastic housing with a snap-on lid. It has RCA jacks, which enable users to connect their electronic device to the vehicle’s audio system so that the sounds coming from the electronic device can be heard through the automobile’s audio system. It is positioned at the back and bottom on the center console of an automobile, making it more accessible from the rear seat.
USB cable is identified within your letter as Part No. 8755A049. It is a 5.6 inch long USB cable, which is fitted with type “A” USB female connectors on both ends. The total length from end to end, including both connectors, is 7.56 inches. The USB cable is used to connect the USB adapter to the automobile’s wireless communication system for data transfer.
You suggested Harmonized Tariff Schedule of the United States (HTSUS) subheading 8544.42.2000, which provides for “Other electric conductors, fitted with connectors, of a kind used for telecommunications” for the USB cable (Part No. 8755A049). However, this particular cable is used to connect an automobile’s internal communication system to a USB adapter jack, which is located within the cab of an automobile. Incorporated with this USB cable is locking block terminals on each end. Locking block terminals are commonly used in the automotive industry to secure wiring harnesses within an automobile. Based on the fact that this USB cable is manufactured for installation within an automobile, the proper classification would be within subheading 8544.30.00, HTSUS, which provides for “Ignition wiring sets and other wiring sets of a kind used in vehicles, aircraft or ships.”
The applicable subheading for the USB adapter (Part No. 8718A007) and USB cable kit (Part No. MZ360331EX) will be 8504.40.9580, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical transformers, static converters (for example rectifiers) and inductors; parts thereof: Static converters: Other: Other.” The rate of duty will be 1.5 percent ad valorem.
The applicable subheading for the audio & video adapter (Part No. 8718A002) will be 8517.70.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as local or wide are network), other than transmission or reception apparatus of heading 8443, 8525, 8527, or 8528; parts thereof: Parts.” The rate of duty will be free.
The applicable subheading for the USB cable (Part No. 8755A049) will be 8544.30.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Ignition wiring sets and other wiring sets of a kind used in vehicles, aircraft or ships.” The rate of duty will be 5.0 percent ad valorem.
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