The tariff classification of seat sensor assemblies from the European Union

N217605 June 11, 2012 CLA-2-85:OT:RR:NC:N1:101 CATEGORY: Classification TARIFF NO.: 8512.90.2000 Thomas Mayer, Global Supply Chain Manager IEE Sensing, Inc. 1121 Centre Road Auburn Hills, MI 48326-2603 RE: The tariff classification of seat sensor assemblies from the European Union Dear Mr. Mayer, In your letter dated May 15, 2012, you requested a tariff classification ruling. The first item being considered is the Seat Belt Reminder (SBR) (Model # 4498). You state that the SBR consists of a sensor mat that is inserted into an automobile seat and detects an occupant in the seat through a series of resistance thresholds (such as short cut, interruption, empty seat and detection of adult occupants) measuring from 48 kilograms to 80 kilograms. The mat is composed of two sandwiched carrier sheets held together by adhesive. The sensor mat includes a PET AG substrate, a PET FSR substrate, acrylic spacers, cable, connectors, fixation adhesive, water-proof membranes, cable crimps, a resistor and printed wires that are made of silver, carbon and resin. The FSR technology in the SBR uses electrical resistance changes to distinguish between empty and loaded seats containing persons or objects. The second item being considered is the Child Seat Presence and Orientation Detection (CPOD) (Model # 3372). You state that the CPOD consists of a sensor mat that is inserted into an automobile passenger seat and is used to detect the presence of a passenger (Passenger Presence Detection-PPD). The PPD function detects the presence of a seat occupant that is heavier than a three (3)-year old child (approximately 12 kilograms in weight). At the time of importation, the sensor incorporates both an SBR function as well as a PPD function. The CPOD sensor mat includes a PET AG substrate, a PET FSR substrate, one transmitting and two receiving antennas, an electronic control unit (ECU), acrylic spacers and fixation adhesives, a cable, action pins, connector, a plastic housing for the ECU and printed wires that are made of silver, carbon and resin. The applicable classification subheading for both the Seat Belt Reminder (SBR) (Model # 4498) and the Child Seat Presence and Orientation Detection (CPOD) (Model # 3372) will be 8512.90.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical … signaling equipment … of a kind used for … motor vehicles; parts thereof: Parts: Of signaling equipment.” 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://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, Thomas J. Russo Director National Commodity Specialist Division