CLA-2-39:OT:RR:NC:N4:421
Mr. Ashok Sadhwani
2815 Military Avenue
Los Angeles, CA 90064
RE: The tariff classification of an automobile smart door handle and cover from South Korea
Dear Mr. Sadhwani:
In your letter dated February 13, 2012, on behalf of Hanil E Hwa Interiors Alabama, you requested a tariff classification ruling.
A sample of an automobile handle and the accessory mounting component for the handle were provided with your letter. The handle and the accessory mounting component are both composed of molded plastics. Part number 82651-3S210 (Sample C) is identified as a smart door handle with electrical components. Part number 82652-3S010 (Sample Cc) is identified as an outside cover, and is a mounting component for the handle. This accessory mounting component may also be imported with the handle rather than being imported as a separate inventory component. The handle has a cable and electronic components that, when connected to a power source, will allow the user to trigger the automobile’s entry system to search for the frequency-operated button. The low frequency antenna receives the frequency signal and relays this information to the automobile’s electronic control system that triggers the opening of the car door lock.
You suggest classification in subheading 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.
Section XVI legal note 1(g) precludes from classification in that section “parts of general use, as defined in note 2 to Section XV, of base metal, or similar goods of plastics.” Parts of general use include items of heading 8302, which provides for, among other articles, base metal mountings, fittings and similar articles suitable for coachwork, including handles. The Explanatory Notes to the Harmonized Commodity Description and Coding System constitute the official interpretation of the HTSUS at the international level. The Explanatory Notes to heading 8302 emphasize that the heading includes goods within such general classes "even if they are designed for particular uses (e.g., door handles or hinges for automobiles)." Plastic handles and accessory mounting pieces for the handles are similar goods of plastics to the articles defined as parts of general use and are thus excluded from classification in any of the subheadings in Section XVI, including subheading 8517.62.0050, HTSUS. Therefore, though the handle has electronic components, it remains essentially a handle, and is excluded from any of the provisions of Section XVI.
The applicable subheading for the door handle, part number 82651-3S210, whether imported alone or imported as a unit consisting of the handle with its accessory mounting component, will be 3926.30.1000, HTSUS, which provides for other articles of plastics: fittings for furniture, coachwork or the like: handles and knobs. The general rate of duty will be 6.5 percent ad valorem.
The applicable subheading for the accessory mounting component, part number 82652-3S010, when imported separately from the handle, will be 3926.30.5000, HTSUS, which provides for other articles of plastics, fittings for furniture, coachwork or the like: other. The general rate of duty will be 5.3 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 Joan Mazzola at (646) 733-3023.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division