The tariff classification of a Manual Window Regulator

NY H89491 March 22, 2002 CLA-2-83:RR:NC:MM:101 H89491 CATEGORY: Classification TARIFF NO.: 8302.30.6000 Mr. Mark Schmittling Cortez Customhouse Brokerage Company 4950 West Dickman Road Battle Creek, Michigan 49015 RE: The tariff classification of a Manual Window Regulator Dear Mr. Schmittling: In your letter dated March 5, 2002 you requested a tariff classification ruling on behalf of Hi-Lex Corporation. You submitted a sample of a Manual Window Regulator that is specifically designed for use in a motor vehicle. It functions to support a window in a vehicle as it is raised and lowered. It is attached to a vehicle’s inner door panel. The parts used to make this manual window regulator consist of a spring, guide rail assembly, brake spring assembly, carrier plate assembly drum, cable guide, housing and drive shaft. The materials to make this assembly are metal, rubber, and plastic. You state that the components used to manufacture the manual window regulator come in bulk from various vendors, both foreign and domestic, and HI-Lex assembles these components into the complete product at its facility in the United States. After assembling the window regulator, Hi-Lex sells the finished product to auto manufacturer assembly plants in North America and Mexico. You suggest that the correct classification for the Manual Window Regulator is HTS 8708.29.5060, which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories of bodies (including cabs): Other: Other…Other; dutiable at 2.5% ad valorem. We disagree with your propose classification because the Explanatory Notes specifically mention window mechanisms as being classified in HTS 8302. The applicable subheading for the Manual Window Regulator will be 8302.30.6000, 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, 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: Of iron or steel, of aluminum or zinc…Other. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). 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