CBP Ruling N302736 — The tariff classification of motion sensors from Germany

Tariff classification

Headings: 8543

Product description

The item under consideration is referred to as the Control Unit ECU FMDM (FMDM), Part Number 31652056, which is described as a plastic bracket, an electronic control unit (ECU), and two capacitive sensors. The two sensors are connected to the ECU that is affixed within the plastic bracket. The entire FMDM assembly is intended to be mounted on the underside of a vehicle adjacent to the rear bumper and is connected to the vehicle’s supervisory controller identified as the central electronics module (CEM). In use, the FMDM creates an electric field under the bumper and after a valid key is detected with the proximity, a person would move their leg or foot beneath the FMDM assembly where the pair of sensors registers the change in field capacitance as voltage feedback to the CEM. The vehicle CEM then initiates the process of opening the rear gate. We would note that the CEM is not subject to this request. In your request you suggest that the FMDM is correctly classified under 8543.70.9960, Harmonized Tariff Schedule of the United States, (HTSUS). We agree.

CBP rationale

The applicable subheading for the Control Unit ECU FMDM (FMDM), Part Number 31652056, will be 8543.70.9960, HTSUS, which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; Other machines and apparatus; …Other”.

Full text

N302736 March 18, 2019 CLA-2-85:OT:RR:NC:N2:220 CATEGORY: Classification TARIFF NO.: 8543.70.9960 Edward Fishburne Volvo Car USA LLC 1801 Volvo Car Drive Ridgeville, SC 29472 RE: The tariff classification of motion sensors from Germany Dear Mr. Fishburne: In your letter dated January 31, 3019 you requested a tariff classification ruling. The item under consideration is referred to as the Control Unit ECU FMDM (FMDM), Part Number 31652056, which is described as a plastic bracket, an electronic control unit (ECU), and two capacitive sensors. The two sensors are connected to the ECU that is affixed within the plastic bracket. The entire FMDM assembly is intended to be mounted on the underside of a vehicle adjacent to the rear bumper and is connected to the vehicle’s supervisory controller identified as the central electronics module (CEM). In use, the FMDM creates an electric field under the bumper and after a valid key is detected with the proximity, a person would move their leg or foot beneath the FMDM assembly where the pair of sensors registers the change in field capacitance as voltage feedback to the CEM. The vehicle CEM then initiates the process of opening the rear gate. We would note that the CEM is not subject to this request. In your request you suggest that the FMDM is correctly classified under 8543.70.9960, Harmonized Tariff Schedule of the United States, (HTSUS). We agree. The applicable subheading for the Control Unit ECU FMDM (FMDM), Part Number 31652056, will be 8543.70.9960, HTSUS, which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; Other machines and apparatus; …Other”. The general rate of duty will be 2.6 percent ad valorem. 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 the 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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