CBP Ruling N280090 — The tariff classification of controllers from Japan or Mexico

Tariff classification

Headings: 8543

Product description

The item under consideration is referred to as the Transmission Control Unit (TCU). The TCU is described as an aluminum enclosure containing a printed circuit board assembly (PCBA) which is used to control automatic transmissions in motor vehicles. The PCBA contains a 32 bit microcontroller, resistors, capacitors, and a single multicontact electrical connector. The TCU is said to receive information from vehicle sensors and determines how and when to change gears to achieve optimum performance, economy, and shift quality. During vehicle operation, the TCU sends electrical signals to solenoids and actuators in order to control the vehicle transmission. In your request, you suggest the TCU is correctly classified under 8537.10.9160 Harmonized Tariff Schedule of the United States (HTSUS), as a programmable controller. However, we would note that the TCU does not meet the terms of the heading for 8537 in that the device does not contain two or more apparatus of 8535 or 8536. As such, the TCU is precluded from classification in heading 8537.

CBP rationale

The applicable subheading for the Transmission Control Unit will be 8543.70.9960, HTSUS, which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere…: Other machines and apparatus: Other: Other: Other: Other.

Full text

N280090 October 25, 2016 CLA-2-85:OT:RR:NC:N4:112 CATEGORY: Classification TARIFF NO.: 8543.70.9960 Ms. Lora Mayo-Brown Robert Bosch LLC 8101 Dorchester Road N. Charleston, S.C. 29418 RE: The tariff classification of controllers from Japan or Mexico Dear Ms. Mayo-Brown: In your letter dated September 29, 2016 you requested a tariff classification ruling. The item under consideration is referred to as the Transmission Control Unit (TCU). The TCU is described as an aluminum enclosure containing a printed circuit board assembly (PCBA) which is used to control automatic transmissions in motor vehicles. The PCBA contains a 32 bit microcontroller, resistors, capacitors, and a single multicontact electrical connector. The TCU is said to receive information from vehicle sensors and determines how and when to change gears to achieve optimum performance, economy, and shift quality. During vehicle operation, the TCU sends electrical signals to solenoids and actuators in order to control the vehicle transmission. In your request, you suggest the TCU is correctly classified under 8537.10.9160 Harmonized Tariff Schedule of the United States (HTSUS), as a programmable controller. However, we would note that the TCU does not meet the terms of the heading for 8537 in that the device does not contain two or more apparatus of 8535 or 8536. As such, the TCU is precluded from classification in heading 8537. The applicable subheading for the Transmission Control Unit will be 8543.70.9960, HTSUS, which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere…: Other machines and apparatus: Other: Other: Other: Other.” The rate of duty will be 2.6%. 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 https://hts.usitc.gov/current. 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 Karl Moosbrugger at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division

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