CLA-2-85:OT:RR:NC:N2:220
Ryan Supek
TE Connectivity Corporation
2800 Fulling Mill Rd.
Middletown, PA 17057
RE: The tariff classification of braking module connection interface from Mexico
Dear Mr. Supek:
In your letter dated February 25, 2022, you requested a tariff classification ruling.
The merchandise under consideration is identified as the Control Unit, Item Number 2302174-8, which is described as a plastic base incorporating multiple bus bars, terminals, and coil/bobbin assemblies that are said to be part of the Integrated Braking Control (IBC) module. You state that the function of the Control Unit is to distribute electrical current via the bus bars and electrically connect the IBC module to the vehicle’s computer.
In your request, you suggest the Control Unit is correctly classified under subheading 8543.70.9860, Harmonized Tariff Schedule of the United States (HTSUS), and you base your opinion on the similarity with the Electronic Control Unit (ECU) considered in NY ruling N270312. As the ECU, discussed in NY N270312, consisted of a printed circuit board assembly and electronics that performed processing and control of a vehicle’s anti-lock braking system, and CBP specifically noted the absence of any electrical switching or protection apparatus of heading 8536, HTSUS, we disagree with the suggested classification.
The applicable subheading for the Control Unit, Item Number 2302174-8 will be 8537.10.9170, HTSUS, which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Other”. The general rate of duty will be 2.7 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 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 Karl Moosbrugger at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division