CLA-2-85:OT:RR:NC:N2:212
Hae Jun Kwon
Hyundai Motor Company
231, Yangjae-dong, Seocho-gu
Seoul 06797
South Korea
RE: The tariff classification of a transmission control unit from Korea
Dear Mr. Kwon:
In your letter dated May 22, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as two models of a Shift By Wire (SBW) Control Unit
Assembly, further identified by part numbers 42950-2D085 and 42950-2N110. You state that the two
versions are virtually identical and function the same with the only difference being the shape of the bracket
that is attached and used to mount the device within a vehicle. The subject device consists of a populated
printed circuit board assembly (PCBA) with an electrical connector at the base, within a metal enclosure. As
noted above, a metal bracket for installation is on the outside of the housing.
In use, the subject assembly is installed within a vehicle and electrically connected to the transmission system
in order to process and control various safety and convenience functions. These features include the
interaction with three main functions of the vehicle. The first is described as a motor control feature. When
the driver changes the transmission lever (i.e. from Park to Drive), the subject unit receives, analyzes and
converts the signal, which notifies the transmission actuator to shift to the appropriate gear position.
The next function is noted as a safety feature that automatically switches the position of the transmission
from either Drive or Reverse to Park if the driver shuts off the car prior to placing the vehicle in Park. The
SBW unit analyzes the conditions of the transmission and the status of the vehicle and makes the appropriate
decision to automatically change the gear position. This function is also used in the event that the vehicle is
turned off while the vehicle is in Neutral. In this case, the SBW will allow the transmission to stay in the
Neutral position in specific instances, such as a car wash.
The final function is described as a Fail Safe function, which monitors and detects the transmission system
for a number of failures and makes the appropriate decision to safely change any gear position. The SBW
assembly is designed to detect failures in various components, such as actuators and sensors, and to switch
the vehicle to a safe mode in the event of an issue. The SBW unit analyzes the failures and sends a signal to
the appropriate unit within the vehicle that will switch the vehicle to a safe condition, such as neutral or park.
In your request, you suggest that the correct classification for the control unit assembly is 8543.70.9860,
Harmonized Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for the SBW Control Unit Assembly, part numbers 42950-2D085 and
42950-2N110, will be 8543.70.9860, HTSUS, which provides for “Electrical machines and apparatus, having
individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and
apparatus: Other: Other: Other: Other.” The general rate of duty will be 2.6% ad valorem.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading
8543.70.9860, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
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 Luke LePage at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division