The tariff classification of a lift gate module and key fob remote from the Philippines

NY G87960 April 2, 2001 CLA-2-85:RR:NC:1:112 G87960 CATEGORY: Classification TARIFF NO.: 8537.10.9070; 8526.92.0000 Mr. Matthew K. Nakachi Three Embarcadero Center, Suite 1160 San Francisco, CA 94111 RE: The tariff classification of a lift gate module and key fob remote from the Philippines Dear Mr. Nakachi: In your letter dated March 1, 2001, on behalf of Temic Telefunken Microelectronic GmbH, you requested a tariff classification ruling. As indicated by the submitted descriptive literature, the lift gate module (LGM) consists of a populated printed circuit board contained within a plastic housing. The board is populated with various electronic components, including relays and connectors. The LGM functions as an on board controller to communicate with other devices within an automobile, as well as to receive user commands from a key fob remote. The key fob remote consists of a plastic housing attached to a key ring. The housing contains a printed circuit board with three switches that can be accessed by the user. These switches, when depressed, generate a radio signal that will result in the locking or unlocking of an automobile’s doors. The applicable subheading for the lift gate module will be 8537.10.9070, Harmonized Tariff Schedule of the United States (HTS), which provides for other boards, panels, …, for electric control or the distribution of electricity, …: For a voltage not exceeding 1,000 V. The duty rate will be 2.7 percent ad valorem. The applicable subheading for the key fob remote will be 8526.92.0000, HTS, which provides for radio remote control apparatus. The duty rate will be 4.9 percent ad valorem. Articles classifiable under subheading 8537.10.9070, HTS, and subheading 8526.92.0000, HTS, which are products of the Philippines, are currently entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations. The GSP, however, is subject to modification and periodic suspension, which may affect the status of your transaction at the time of entry for consumption or withdrawal from warehouse. To obtain current information on GSP, check the Customs Web site at www.customs.gov. At the Web site, click on "CEBB" and then search for the term "GSP". 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 David Curran at 212-637-7049. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division