The tariff classification of plastic reflectors from Slovakia

N099117 April 19, 2010 CLA-2-87:OT:RR:NC:N1:101 CATEGORY: Classification TARIFF NO.: 8708.99.8180 Robert Resetar, Customs Manager Porsche Cars North America, Inc. 980 Hammond Drive NE, Suite 1000 Atlanta, GA 30328-6163 RE: The tariff classification of plastic reflectors from Slovakia Dear Mr. Resetar, In your letter dated March 26, 2010, you requested a tariff classification ruling. The article under consideration is a Rear Bumper Reflector which you state is to be mounted in an indentation on the rear bumper of a Porsche vehicle. The Reflector is made of red, molded plastic and its function is to reflect light from approaching oncoming vehicles and add to the aesthetics of a vehicle. In your request, you propose classification of the Rear Bumper Reflector in subheading 8708.10.6050 of the Harmonized Tariff Schedule which provides for “ … accessories of … motor vehicles … : Parts of bumpers: Other.” The Reflector is not part of a vehicle bumper. The bumper is an article in, and of, itself, and performs its protective function without need of the Reflector. The Reflector is an accessory to a bumper that fulfills an entirely different function. 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 ... .” General Note 3. (h) (vi) to the HTSUS states “ ... a reference to ‘headings’ encompasses subheadings indented thereunder.” Subheading 8708.99 of the HTSUS provides for “ ,,, accessories of … motor vehicles … : Other … accessories: Other.” The applicable classification subheading for the Rear Bumper Reflector will be 8708.99.8180, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “ … accessories of … motor vehicles … : Other … accessories … : Other: Other: Other: Other: Other: Other.” 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 Harmonized Tariff Schedule of the United States and the accompanying duty rates are provided on the World Wide Web at http://ww.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