The tariff classification of four automobile parts – Bumper Absorbers from Japan

NY I81344 May 15, 2002 CLA-2-87:RR:NC:MM:101 I81344 CATEGORY: Classification TARIFF NO.: 8708.29.5060 Ms. Mary Elizabeth Strom Customs Department American Honda Motor Co., Inc. 1919 Torrance Boulevard Torrance, California 90501-2746 RE: The tariff classification of four automobile parts – Bumper Absorbers from Japan Dear Ms. Peach: In your letter dated April 11, 2002 you requested a tariff classification ruling. You submitted drawings for four automobile Bumper Absorbers. Bumper Absorber – Part Number 71170-S30-A00 – The bumper absorber is a component of the front bumper that serves to protect the vehicle from the impact of a collision. The bumper is one of three major components that together form the complete bumper. It is formed to allow for the attachments that secure it in between the bumper beam and the bumper fascia. It extends the width of the vehicle and by itself would provide protection in minor impacts. Bumper Absorber – Part Number 71171-ST7-A10 - The bumper absorber is a component of the front bumper that serves to protect the vehicle from the impact of a collision. The bumper is one of three major components that together form the complete bumper. It is formed to allow for the attachments that secure it in between the bumper beam and the bumper fascia. It extends the width of the vehicle and by itself would provide protection in minor impacts. Bumper Absorber – Part Number 71570-SD4-670 - The bumper absorber is a component of the front bumper that serves to protect the vehicle from the impact of a collision. The two-piece bumper is one of three major components that together form the complete bumper. It is in two separate pieces to allow for insertion of the license plate, which is sunk into the bumper. The bumper absorbers are formed to allow for the attachments that secure it in between the bumper beam and the bumper fascia. Both pieces extend the width of the vehicle and together they provide protection in a minor impact. Bumper Absorber – Part Number 71570-SK7-A01 - The bumper absorber is a component of the rear bumper that serves to protect the vehicle from the impact of a collision. The two-piece bumper is one of three major components that together form the complete bumper. It is in two separate pieces to allow for insertion of the license plate, which is sunk into the bumper. The bumper absorbers are formed to allow for the attachments that secure it in between the bumper beam and the bumper fascia. Both pieces extend the width of the vehicle and together they provide protection in a minor impact. You state that the first two parts are bumper absorbers that are used to protect a vehicle in the event of a collision. Each enhances the function of the bumper. While each of these absorbers does absorb some of the energy of an impact, it is your belief that they are neither complete nor stand-alone bumpers. In regards to the third and fourth bumper absorbers, instead of one solid beam extending the width of the vehicle, they are composed of two individual beams. The sole reason for the break in the beam is to allow the license plate to sit within the bumper. The split pieces, which serve to accommodate the license plate, still provide the same function as the single beam absorber when mounted onto the vehicle. Both styles are fitted and mounted in between the bumper beam and bumper fascia and each can protect the body in minor collisions. The parts also absorb some of the energy from an impact, but you state that you feel that these are not enough to compose a complete or stand-alone bumper. The applicable subheading for the four Bumper Absorbers 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% 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 646-733-3008. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division