CLA-2-83:RR:NC:MM:101 F82671

Mr. Mitchell Neriah
Mitchell Neriah Customs Consulting Services
415 S. Prospect Avenue, Suite 110
Redondo Beach, California 90277

RE: The tariff classification of aluminum "stiffeners" (brackets) from Japan

Dear Mr. Neriah:

In your letter dated February 1, 2000 you requested a tariff classification ruling on behalf of your client Calhac, Inc.

You submitted photographs and engineering drawings of two aluminum "stiffeners" (brackets) used to secure an electric storage battery and power control unit within an automobile body. The two parts (Calhac part # 1B880-PHM-000 and 1B890-PHM-000) are used to secure a nickel-hydride electric storage battery used to power a hybrid electric-internal combustion powered motor vehicle to an "IMA-PCU" (integrated motor assist power control unit) module. The battery and the IMA-PCU are the two main components of the electric power delivery system of the hybrid automobile. They are located behind the passenger seats within the automobile, and are encased in an aluminum compartment.

The function of these two aluminum parts is to secure the battery and the IMA-PCU together within their compartment in the automobile. The stiffeners will assist in keeping the battery and IMA-PCU in their proper locations and distance from each other.

Part # 1B880-PHM-000 is a hollow aluminum tube, bent to shape, with its two ends flattened and pressed together. There are 8 mm diameter holes in each flattened end, and another flattened protrusion with a bolt hole welded to the part near its middle. It is approximately 230 mm in length and 22 mm wide.

Part # 1B890-PHM-000) is a hollow aluminum tube, bent to shape, with its two ends flattened and pressed together. There are two 8 mm diameter bolt holes on each end. The part is approximately 261.5 mm in length and 22 mm wide.

The applicable subheading for the aluminum "stiffeners" (brackets) will be 8302.30.3060, Harmonized Tariff Schedule of the United States (HTS), which provides for Base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork…; and base metal parts thereof: Other mountings, fittings and similar articles suitable for motor vehicles: and parts thereof: Of iron or steel, of aluminum or zinc: Other. The rate of duty will be 2% ad valorem.

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 212-637-7035.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division