CLA-2-40:OT:RR:NC:N1:137
Matthew Moore
Nissan North America, Inc.
One Nissan Way
Franklin, TN 37067
RE: The tariff classification of three types of bushings from Japan
Dear Mr. Moore:
In your letter dated January 24, 2019 you requested a tariff classification ruling.
The merchandise at issue consists of three types of bushings, identified by the part numbers 55157EA501, 8200568119, and 551350W000. You indicate that they are intended to absorb vibrations in specified locations within an automobile.
Part # 55157EA501 is described as a Steering Knuckle Bushing. It is comprised of an inner and outer collar of steel with an insulator in the middle composed of a mixture of natural rubber and butadiene rubber where the natural rubber predominates by weight.
Part # 8200568119 is described as a Rear Axle Bushing. It is comprised of an inner collar of steel, outer collar of plastic and an insulator in the middle composed entirely of natural rubber.
Part # 551350W000 is described as a Suspension Link Rod Bushing. It is comprised of an inner collar of steel and an outer insulator composed entirely of natural rubber.
In all three bushings, it is the rubber component that controls the vibrations within an automobile. The steel components are merely there to facilitate contact of the bushing with the frame of the automobile. Therefore, it is the rubber component that imparts the essential character of each of these parts.
The applicable subheading for the bushings will be 4016.99.3000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of vulcanized rubber other than hard rubber: other: of natural rubber: vibration control goods of a kind used in the vehicles of headings 8701 through 8705. The rate of duty will be free.
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 the 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 Christina Allen at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division