The tariff classification of the Clip for Starter, Clip for Marine Starter, Cap for Starter and Plug Extension for Starter made in Taiwan and China

N032381 July 22, 2008 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7326.90.8587; 7419.99.5050 Ms. Danivia Vasconcelos C.C.S. Certified Customs & Traffic Manager RCP, Inc. 2891 Langstaff Road L4K 4Z2 – Concord Ontario, Canada RE: The tariff classification of the Clip for Starter, Clip for Marine Starter, Cap for Starter and Plug Extension for Starter made in Taiwan and China Dear Ms. Vasconcelos: In your letter dated June 24, 2008, you requested a tariff classification ruling. Samples of the Clip for Starter, the Clip for Marine Starter, the Cap for Starter and the Plug Extension for Starter were submitted with your ruling request for our review. The merchandise is identified in your letter as the Clip for Starter (part number 21546), the Clip for Marine Starter (part number 41598), the Cap for Starter (part number 50221) and the Plug Extension for Starter (part number 85322). The Clip for Starter is an electrical copper contact point for a starter motor. The Clip for Marine Starter is a flat stamped steel grounding strap that mounts to marine alternators with an exposed threaded hole to enable connection to the system grounding network. The Cap for Starter is a steel plug for a lubrication cavity in a starter motor housing which keeps the oil wick from falling out and dirt from entering. The Plug Extension is a steel plug for an access point to allow for adjustment to the starter motor shift lever positioning. You stated that the clips and the cap will be made in Taiwan and the plug extension will be made in China. In your ruling request, you proposed that the Clip for Starter (part number 21546), the Clip for Marine Starter (part number 41598), the Cap for Starter (part number 50221) and the Plug Extension for Starter (part number 85322) be classified in Harmonized Tariff Schedule of the United States (HTSUS), subheading 8511.90.6040 which provides for “ … starter motors … : Parts: Other parts: Other”.  Note 1.(g) to Section XVI of the HTSUS, of which Chapter 85 is a part, specifies that “This section does not cover … Parts of general use … of base metal … ”.  The Clip for Starter (part number 21546), the Clip for Marine Starter (part number 41598), the Cap for Starter (part number 50221) and the Plug Extension for Starter (part number 85322) are “parts of general use” as defined by Note 2. to Section XV of the HTSUS. The samples will be returned as you requested. The applicable subheading for the Clip for Marine Starter (part number 41598), the Cap for Starter (part number 50221) and the Plug Extension for Starter (part number 85322)) will be 7326.90.8587, HTSUS, which provides for other articles of iron or steel, other, other, other, other, other. The rate of duty will be 2.9 percent ad valorem. The applicable subheading for the Clip for Starter (part number 21546) will be 7419.99.5050, HTSUS, which provides for other articles of copper, other, other, other, other, other. The rate of duty will be free. 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 Ann Taub at 646-733-3018. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division