The tariff classification of steel guide clips and plastic sunroof knobs from Japan.

NY C89088 August 8, 1998 CLA-2-87:RR:NC:MM:101 C89088 CATEGORY: Classification TARIFF NO.: 8302.30.3060, 3926.30.1000 Mr. Carlos R. Juelle Stein, Shostak, Shostak & O'Hara Suite 1200 515 Figueroa Street Los Angeles, California 90071-3329 RE: The tariff classification of steel guide clips and plastic sunroof knobs from Japan. Dear Mr. Juelle: In your letter dated June 30, 1998 you requested a tariff classification ruling on behalf of your client, Aisin World Corporation of America in Torrance California. The first item is a steel spring type guide which keeps the automotive sunroof straight when it is being opened and closed. The second item is a plastic sunroof knob which is used to manually open and close the sunroof. You have suggested that the correct classification for both items would be 8708.29.5060 which provides for other body parts. Section XVII of the Harmonized Tariff Schedule of the United States (HTS) indicates in Note 2 (b): "The expressions parts' and parts and accessories' do not apply to the following articles, whether or not they are identifiable as for the goods of this section: (b) Parts of general use, as defined in note 2 to section XV, of base metal (Section XV) or similar goods of plastics (chapter 39)." Section XV Note 2 (c) indicates: "Throughout the tariff schedule, the expression parts of general use' means:(c) Articles of heading 8301, 8302, 8308, or 8310 and frames and mirrors of base metal, of heading 82306." Subheading 8302.30 (HTS) applies to: "Base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like; base metal hat racks, hat-pegs, brackets and similar fixtures; castors with mountings of base metal; automatic door closers of base metal; and base metal parts thereof:..Other mountings, fittings and similar articles suitable for motor vehicles; and parts thereof.." It is our opinion that the spring clip guides and knobs are fittings in the meaning of Subheading 8302.30(HTS). The guides are of base metal and should be classified in Heading 8302. The knobs are plastic, but are similar to the goods described in Heading 8302, and should therefore be classified in Chapter 39 (HTS). The applicable subheading for the spring clip guides 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...Other mountings fittings and similar articles suitable for motor vehicles; and parts thereof: Of iron or steel, of aluminum or of zinc...Other.. The rate of duty will be 2.2 percent ad valorem. The applicable subheading for the plastic sunroof knobs will be 3926.30.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of plastics and articles of other materials of headings 3901 to 3914...Fittings for furniture, coachwork or the like: Handles and knobs. The rate of duty will be 6.5 percent 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 212-466-5667. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division