CLA-2-87:OT:RR:NC:N1:101
Jini Koh
Crowell & Moring, LLP
1001 Pennsylvania Avenue NW
Washington, DC 20004-2595
RE: The tariff classification of clutch discs from multiple countries
Dear Ms. Koh,
In your letter dated March 28, 2012, you requested a tariff classification ruling on behalf of Aisin Holdings of America, Inc. of Torrance, California.
The items being considered are three (3) Clutch Discs (Part Numbers 37500-9V677-C/DF-105, 37500-99019-G/DM-301L, 37500-9V567-H/DS-022). Clutch Discs are rotating circular steel plates covered with a friction material, approximately 170 to 275 millimeters in diameter, used solely within the clutch assembly of a motor vehicle. The Clutch Disc is located between the engine flywheel and the clutch pressure plate; it is clamped tightly between these two components when the clutch is engaged, thus transmitting power from the flywheel through the clutch and into the transmission, causing them to turn at the same rate of speed.
The applicable classification subheading for the Clutch Discs (Part Numbers 37500-9V677-C/DF-105, 37500-99019-G/DM-301L, 37500-9V567-H/DS-022) will be 8708.93.7500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts … of … motor vehicles … : Other parts … : Clutches and parts thereof: For other vehicles: Other.” The rate of duty will be 2.5%.
Your inquiry does not provide enough information for us to make a classification determination on any Clutch Discs other than the three (3) specified above. Your request for a classification ruling must include sufficient information to determine a proper tariff classification, such as: a full and complete description of each article, in the condition in which it will be imported; the article’s principal use in the United States; the commercial, common, or technical designation and illustrative literature. In addition, Ruling requests may only contain a maximum total of 5 items in order to be accepted.
With regard to your request for classification of a Clutch Release Cylinder, this Office is precluded from ruling on an issue that is currently pending before Customs. The classification determination of a similar item has previously been forwarded to Customs Headquarters for resolution. A ruling on this product cannot be issued until the matter is resolved.
Duty rates are provided for your convenience and are subject to change. The text of the most recent Harmonized Tariff Schedule of the United States and the accompanying duty rates are provided on the World Wide Web at http://ww.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 Richard Laman at 646-733-3017.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division