The tariff classification of vehicle suspension parts

N092976 February 25, 2010 CLA-2-87:OT:RR:NC:N1:101 CATEGORY: Classification TARIFF NO.: 8708.80.6590 Mr. Donald S. Simpson, Senior Vice President Barthco 5101 S. Broad Street Philadelphia, PA 19112-1404 RE: The tariff classification of vehicle suspension parts Dear Mr. Simpson: This replaces Ruling Number N003269, dated November 28, 2006, which contained clerical errors: the two (2) parts referenced in the ruling were each missing a digit in their part numbers. Pursuant to title 19, United States Code, Section 3005, the Harmonized Tariff Schedule of the United States (HTSUS) was amended effective 1/1/07. Accordingly, this amendment is also reflected in this ruling. A complete corrected ruling follows. In your letter dated November 2, 2006, you requested a tariff classification ruling on behalf of your client, SKF USA, Inc. of Norristown, Pennsylvania. The two items concerned are parts of a McPherson strut assembly. Their product numbers are BDA1080CA and BDA1078A. These two (2) parts are located in the strut assembly between the coil spring and the structure of the vehicle. Their function is to allow free rotation of the top of the spring that normally occurs when a coil spring is compressed and to allow rotation of the complete strut assembly when used with suspensions for steered wheels. Each article is an assembly of two steel thrust washers, steel balls and a cage contained in a plastic enclosure. The washers, balls and cage form a thrust bearing with the washers serving as raceways and the balls as rolling elements. The enclosure is formed by two pieces of plastic that snap together to form a housing for the bearing. The housing serves to align the axis of the bearing with the axis of the strut assembly and facilitates mounting the bearing between the fixed vehicle structure and the rotating coil spring. The applicable subheading for both the BDA1080CA and BDA1078A will be 8708.80.6590, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts … of … motor vehicles … : Suspension systems and parts thereof … : Parts: Other: Other: Other. The general 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/. 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