CLA-2-87:RR:NC:MM:101 R00692

Mr. Robert Resetar
Porsche Cars North America, Inc.
980 Hammond Drive
Suite 1000
Atlanta GA 30328

RE: The tariff classification of bumper caps and spoiler caps from Germany.

Dear Mr. Resetar:

In your letter dated August 12, 2004 you requested a tariff classification ruling.

The first item is a bumper cap. The bumper cap is made of plastic. It snaps onto the bumper fascia to cover the towing lug access hole. If the car needs to be towed, the bumper cap is pried off with a screwdriver. A Devil’s tail attached to the cap keeps it tethered to the bumper fascia. Behind the cap, is a threaded hole in the bumper rail ; where a large steel eyelet shaped towing lug is screwed.

The second item is a spoiler cap. It is made of plastic. It has the exact same function as the bumper cap, only it is located on the lower bumper spoiler and does not have a Devil’s tail tether.

The applicable subheading for the bumper cap will be 8708.10.6050, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Bumpers and parts thereof: Parts of bumpers: Other. The rate of duty will be 2.5 percent.

The applicable subheading for the spoiler cap will be 8708.29.5060, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories of bodies: Other: other. The rate of duty will be 2.5 percent.

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 Robert DeSoucey at 646-733-3008.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division