CLA-2-87:OT:RR:NC:N1:101
Tracey Topper Gonzalez
Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP
399 Park Avenue, 25th Floor
New York, NY 10022-4877
RE: The tariff classification of steel emergency stops from Germany
Dear Ms. Gonzalez,
In your letter dated November 12, 2012, you requested a tariff classification ruling on behalf of ThyssenKrupp Presta Terre Haute of Terre Haute, Indiana. Per your request, the two (2) samples you provided will be returned to your attention.
The first item being considered is the “Steel Emergency Stop” (Part # 705464). You state that the “Steel Emergency Stop” is a one-piece item which is specifically designed for use in the steering power column of an automobile. It consists of a short, tubular piece of steel with a threaded attachment on its opposite end; there is a star-shaped indent in the center of the tubular end. It measures approximately ½ inch in length.
The second item being considered is the “Steel Emergency Stop” (Part # 514742). You state that the “Steel Emergency Stop” is a two-piece item which is specifically designed for use in the steering power column of an automobile. Each of the two (2) parts is a tubular piece of steel with a hole through its center. One end of each Stop is flat and the other end is beveled. Each measures approximately ¼ inch in length.
The “Steel Emergency Stops” prevent the steering column (and steering wheel) from tilting too far, in either the up or down positions, in order to adjust to the height or position of the driver. They are attached to the swing bracket, which holds the spindle and swings up and down in the inner bracket. To limit the tilt of the swing bracket (and thus the spindle and steering wheel), the stop comes in contact with the inner bracket at the end of its range of motion.
The applicable classification subheading for the “Steel Emergency Stop” (Part # 705464) and the “Steel Emergency Stop” (Part # 514742) will be 8708.94.7550, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Parts … of … motor vehicles … : Other parts … : … steering columns … ; parts thereof: Parts: For other vehicles: Other: Other." The rate of duty will be 2.5%.
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://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 Richard Laman at 646-733-3017.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division