The tariff classification of automotive electronic ignition equipment.

NY M85309 August 24, 2006 CLA-2-85:RR:NC:N1:101 M85309 CATEGORY: Classification TARIFF NO.: 8511.80.6000, 8511.90.6040 Ms. Lora Mayo-Brown Robert Bosch Corporation 8101 Dorchester Road N. Charleston S.C. 29418 RE: The tariff classification of automotive electronic ignition equipment. Dear Ms. Mayo-Brown: In your letter dated July 21, 2006 you requested a tariff classification ruling. The items are a complete Theft Deterrent Module and one of its parts. The complete Module’s primary function is to ensure that only the proper learned keys are able to allow the vehicle to start. The coil creates an inductive field which temporarily generates power to the micro chip in the key, and simultaneously, the circuit board generates a request for ID that is received by the micro chip on the key. The key then transmits the correct ID number through the coil to the circuit board. The processor on the circuit board verifies the ID number and authorizes the ignition circuit to start the automobile. You will be importing PK3 security modules with and without the circuit board. The applicable subheading for the PK3 with the circuit board will be 8511.80.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Electrical ignition or starting equipment of a kind used for spark-ignition or compression-ignition internal combustion engines (for example, ignition magnetos, magneto-dynamos, ignition coils, spark plugs and glow plugs, starter motors); generators (for example, dynamos, alternators) and cut-outs of a kind used in conjunction with such engines; parts thereof: Other equipment: Other. The rate of duty will be 2.5 percent. The applicable subheading for the PK3 without the circuit board will be 8511.90.6040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Electrical ignition or starting equipment of a kind used for spark-ignition or compression-ignition internal combustion engines (for example, ignition magnetos, magneto-dynamos, ignition coils, spark plugs and glow plugs, starter motors); generators (for example, dynamos, alternators) and cut-outs of a kind used in conjunction with such engines; parts thereof: Parts: Other parts: Other. The rate of duty will be 2.5 percent. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/. You have suggested HTS number 8543.89.9795 as the correct classification. We find, however that these goods are more specifically provided for in heading 8511 which covers ignition equipment for the internal combustion engines which are used in motor vehicles. 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