CLA-2-40:OT:RR:NC:N4:421
Mr. Michael Unsworth
JAS Forwarding (USA), Inc.
35790 Northline Rd., Suite B
Romulus, MI 48174
RE: The tariff classification of rubber plugs, bumpers and dampers from China
Dear Mr. Unsworth:
In your letter dated August 27, 2012, on behalf of Zhongli North America, you requested a tariff classification ruling.
The five samples provided with your letter are all composed of ethylene propylene diene monomer (EPDM) synthetic rubber and will be used in automobiles. Article number 68073368AA, identified as a pillar covering, is a circular plug used to seal a hole on the A-pillar to prevent water leaks. Article number 06106186AA, identified as a fastener, is a circular plug used on a floor pan to prevent water leaks. Article number 68071989AA, identified as a liftgate bumper/adjustable hood bumper, is a cylindrical component used to adjust the hood height to make it flush. Article number 68073365AB, identified as a hood fixed bumper, is a round component used to prevent metal to metal contact when the hood is closed. Article 68073366AA, identified as a fixed hood damper/hood adjustable bumper, is a cylindrical component used to adjust the hood height to make it flush. As you requested, the samples will be returned.
You suggest classification of all five styles in subheading 4016.99.6050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of vulcanized rubber, other. Although we agree with this classification for three of the products, the two plugs are more specifically provided for in a previous subheading of the tariff.
The applicable subheading for article number 68073368AA, the A-pillar plug, and article number 06106186AA, the floor pan plug, will be 4016.99.1500, HTSUS, which provides for other articles of vulcanized rubber other than hard rubber: other: caps, lids, seals, stoppers and other closures. The rate of duty will be 2.7 percent ad valorem.
The applicable subheading for article number 68071989AA, the liftgate bumper, article number 68073365AB, the hood fixed bumper, and article 68073366AA, the fixed hood damper, will be 4016.99.6050, HTSUS, which provides for other articles of vulcanized rubber other than hard rubber, other. The rate of duty will be 2.5 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