The tariff classification of trailer parts from China

N127204 November 5, 2010 CLA-2-87:OT:RR:NC:N1:101 CATEGORY: Classification TARIFF NO.: 8716.90.5060 T.L. McCracken, Vice President - Customs Administration Supply Chain Shipping LLC 4607 44th Street S.E. Kentwood, MI 49512-4014 RE: The tariff classification of trailer parts from China Dear Mr. McCracken, In your letter received on October 13, 2010, you requested a tariff classification ruling on behalf of your client, Wabash National, LP. of S. Lafayette, Indiana. The items under consideration have been identified as five (5) parts used in the construction of a semi-trailer. The first item, Coupler Assembly (Part # 03003671), partly supports the load within the trailer and is the interface coupling between the trailer and tractor. The upper Coupler is made of several mechanically punched or bent hot-rolled, cold-finished components that are welded into an assembly. The second and third items, Front Dividers (Part #’s 03S06973 & 03S07036), are the bracings for the forward section of the upper Coupler. The Dividers provide lower plate stiffness when coupling and un-coupling with the tractor. The Front Dividers are made of hot-rolled 50 ksi material that is cold-formed mechanically by punching in a press operation. You state that the Dividers are received in a finished condition and are welded within a Coupler Assembly. The fourth item, King Pin Channel (Part # 03S05182), is a bracing support for the King Pin (a coupling pin between a tractor and trailer) within the main assembly of the upper Coupler. The Channel provides multi-axis support for the King Pin and stiffness within the main assembly when coupling and un-coupling with the tractor. The King Pin Channel is made of hot-rolled 50 ksi material that is cold-formed mechanically by punching in a press operation. You state that the part is received in a finished state and is welded within a Coupler Assembly. The final item, AFT Hat X-Member Assembly (Part # 02002841), is a transverse crossmember fitted to the bottom side rails of a trailer to support the floor. It supports internal loads during both mobile and non-mobile functions. As referenced in your request, this type of part is imported under various part numbers which uniquely identify changes in length, mounting holes, etc. The Assembly is received in finished condition and subsequently bolted within the trailer assembly. The applicable classification subheading for the Coupler Assembly (Part # 03003671), Front Dividers (Part #’s 03S06973 & 03S07036), King Pin Channel (Part # 03S05182) and AFT Hat X-Member Assembly (Part # 02002841) will be 8716.90.5060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “ … semi-trailers; … and parts thereof: Parts: Other: Other.” The rate of duty will be 3.1%. 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