CLA-2-85:OT:RR:NC:N2:220
Ryan Supek
TE Connectivity Corporation
2800 Fulling Mill Road
Middletown, PA 17057
RE: The tariff classification of connector seals from China and Canada
Dear Mr. Supek:
In your letter dated August 31, 2018 you requested a tariff classification ruling.
There are five items submitted for consideration which you refer to as connector seals. Each of the seals are comprised of silicone rubber and are used in various electrical connectors.
The first item is identified as the 6-Position Interface Seal, PN 794275-1, which is described as a molded silicone rubber seal used with a Universal Mate-N-Lok connector to create a splash-proof/immersible sealed electrical connection between a mated plug and cap housing. You state that the 6-Position Interface Seal is made in China.
The second item is identified as the Single Wire Seal, PN 794758-1, which is described as a molded silicone rubber seal used with a Mini-Universal Mate-N-Lok connector to create a water and dust resistant electrical connection around the contact cavity of the connector housing. You state that the Single Wire Seal is made in Canada.
The third item is identified as the Cavity Plug Seal, PN 794995-1, which is described as a molded silicone rubber seal used with a Mini-Universal Mate-N-Lok connector to create a water and dust resistant electrical connection around the opening of an unused contact cavity. You state that the Cavity Plug Seal is made in China.
The fourth item is identified as the 6-Position MCON Mat Seal, PN 2138290-1, which is described as a molded silicone rubber seal used with an MCON connector housing assembly to create a water and dust resistant electrical connection in motor vehicle wiring applications. The 6-Position MCON Mat Seal is also referred to as the Rear Seal and encapsulates the electrical contacts. You state that the 6-Position MCON Mat Seal is made in China.
The fifth item is identified as the Peripheral Seal, PN 2098221-1, which is described as a molded silicone rubber seal used with an MCON connector housing assembly to create a water and dust resistant electrical connection in motor vehicle wiring applications. You state the Peripheral Seal is made in China.
In your request you suggest the 6-Position MCON Mat Seal and the Peripheral Seal are properly classified in subheading 8538.90.6000, Harmonized Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for the 6-Position Interface Seal, PN 794275-1, the Single Wire Seal, PN 794758-1, the Cavity Plug Seal, PN 794995-1, the 6-Position MCON Mat Seal, PN 2138290-1, and the Peripheral Seal, PN 2098221-1, will be 8538.90.6000, HTSUS, which provides for molded parts suitable for use solely or principally with the apparatus of heading 8535, 8536, or 8537. The duty rate will be 3.5 percent ad valorem.
Effective July 6, 2018, the Office of the United States Trade Representative imposed an additional tariff on certain products of China classified in the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), HTSUS. For additional information see “Notice of Action and Request for Public Comment Concerning Proposed Determination of Action Pursuant to Section 301: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation” (June 20, 2018, 83 F.R. 28710). Products of China that are provided for in subheading 9903.88.01 and classified in one of the subheadings enumerated in U.S. note 20(b) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees and charges that apply to such products, as well as to those imposed by subheading 9903.88.01.
Products of China classified under subheading 8538.90.6000, HTSUS, unless specifically excluded, are subject to the additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheading 8538.90.6000, HTSUS, listed above.
The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading.
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 https://hts.usitc.gov/current.
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 Karl Moosbrugger at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division