CLA-2-87:OT:RR:NC:N2:206
Daniel Cannistra
Crowell & Moring, LLP
1001 Pennsylvania Avenue NW
Washington, DC 20004-2595
RE: The tariff classification of a thermoplastic sheet from Germany.
Dear Mr. Cannistra:
In your letter dated June 19, 2020, you requested a tariff classification ruling on behalf of your client, Valeo North America, Inc. Pictures and other descriptive literature were submitted with your request.
The item under review is a Thermoplastic Sheet (Part Number T36765B) used in automotive applications. The thermoplastic sheet is used for the reinforcement of a front end carrier (FEC), which is the part of a car that supports most of the cooling system, headlights, and various other components. These components are mounted on the FEC. The subject part is made of TEPEX, a thermoplastic composite material combining fibers and thermoplastic polymers. It is made through the process of injection molding, which is then assembled with other components to create the front end carrier. Based on the pictorial diagrams submitted with your request, the thermoplastic sheet is not of a regular geometric shape.
In your letter, you discuss a possible classification of the thermoplastic sheet in heading 3921, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other plates, sheets, film, foil and strip, of plastics…” However, as you note in your letter, to be considered plastic sheets of headings 3920 or 3921, one of the main requirements is that they have to be cut into regular geometric shapes. The component under review is clearly not in any geometric shape, and is cut in such a way that makes it identifiable for use specifically with motor vehicles. As a result, the thermoplastic sheet is precluded from classification in headings 3920 or 3921, HTSUS.
The applicable subheading for the Thermoplastic Sheet (Part Number T36765B) will be 8708.29.5060, HTSUS, which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories of bodies (including cabs): Other: Other: Other.” The general rate of duty will be 2.5% 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 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, please contact National Import Specialist Liana Alvarez at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division