The tariff classification of Steering Wheel Armatures from Brazil, the United States and Germany

N007218 March 1, 2007 CLA-2-87:RR:NC:N1:101 CATEGORY: Classification TARIFF NO.: 8708.94.5000 Kelton M. Moore, Vice President of Operational Support TK Holdings, Inc. 422 Gallimore Dairy Road Greensboro, NC 27409-9725 RE: The tariff classification of Steering Wheel Armatures from Brazil, the United States and Germany Dear Mr. Moore: In your letter dated February 12, 2007 you requested a tariff classification ruling. The item concerned is a steel magnesium alloy Steering Wheel Armature. It is dull silver and measures approximately 14 inches across and 4 ½ inches high. The Steering Wheel Armature is pre-holed and includes a toothed center ring. The function of the Steering Wheel Armature is to allow the operator of a vehicle to steer the vehicle in a desired direction. You propose in your Ruling Request that the Steering Wheel Armature is classifiable in subheading 8708.94.7550, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts…of … motor vehicles… : Other parts… : Steering wheels… : Parts: For other vehicles: Other: Other.” Classification of goods in the Harmonized Tariff Schedule of the United States (HTSUS) is governed by the General Rules of Interpretation (GRIs). GRI 1. states, “ ... classification shall be determined according to the terms of the headings...“. GRI 2.(a) states, “Any reference in a heading to an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as entered, the incomplete or unfinished article has the essential character of the complete or finished article.”. The Steering Wheel Armature has the essential character of a steering wheel. General Note 3.(h)(vi) to the HTSUS states, “ ... a reference to “headings” encompasses subheadings indented thereunder.”. Subheading 8708.94 provides for “…Steering wheels…”. The applicable subheading for the Steering Armature will be 8708.94.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts…of … motor vehicles…: Other parts… : Steering wheels… : Steering wheels… : For other vehicles”. The rate of duty will be 2.5%. 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/. 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 Richard Laman at 646-733-3017. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division