The tariff classification of vehicle marker and reverse lights from Mexico and/or Germany

 N316414 January 4, 2021 CLA-2-85:OT:RR:NC:N2:201 CATEGORY: Classification TARIFF NO.: 8512.20.4040 Timothy A. Rombach Daimler Trucks North America 4555 North Channel Ave. Portland, OR 97217 RE: The tariff classification of vehicle marker and reverse lights from Mexico and/or Germany Dear Mr. Rombach: In your letter dated December 10, 2020, you requested a tariff classification ruling. The first item under consideration has been identified as marker lights used on heavy-duty commercial vehicles. In your request, you state that you intend to import complete assemblies. This would include the lens, incandescent or led lamp, housing, electrical wiring and sockets. The marker lights will be in various shapes and sizes. You state the items are used solely with vehicles of Chapter 87. Marker lights are used to assist in making vehicles conspicuous and visible with respect to its presence and dimensions. They are mounted in various locations on the exterior of commercial vehicles, for example, cab roof, sidewalls, bumper, mirror, etc. The second item under consideration has been identified as reverse lamps used on heavy-duty commercial vehicles. In your request, you state that you intend to import the complete assembly. This would include the lens, incandescent or led lamp, housing, electrical wiring and sockets. They will be in various shapes and sizes. The items are used solely with vehicles of Chapter 87. Reverse lamps (also known as backup lights) are located at the rear of commercial vehicles, near the turn signals and brake lights. Reverse lamps are usually white or clear and used to warn other vehicles and pedestrians that a vehicle is about to move backwards. These types of vehicle lamps also provide some illumination when the vehicle is backing up. In your request you suggest that primary function of the reverse lamp is to provide a visual signal to other drivers and pedestrians that a vehicle is about to move backwards and is properly classified in 8512.20.4040 as visual signaling equipment. We agree. The applicable subheading for both the marker and reverse lights will be 8512.20.4040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical lighting or signaling equipment…, windshield wipers, defrosters and demisters, of a kind used for cycles or motor vehicles; parts thereof: Other lighting or visual signaling equipment: Lighting equipment: For the vehicles of subheading 8701.20 or heading 8702, 8703, 8704, 8705 or 8711”. The rate of duty will be Free. 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 Matthew Sullivan at matthew.sullivan.cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division