Jan. 20 CBP Bulletin Proposes to Revoke Rulings on Clutch Cylinders, Differential Assemblies
In the Jan. 20 issue of the CBP Customs Bulletin (Vol. 50, Nos. 2 and 3) (here), CBP published notices that propose to revoke or modify rulings and similar treatment for clutch master cylinders and clutch slave cylinders, and parts of front differential and rear differential assemblies for motor vehicles.
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Comments on Proposals Due Feb. 19
CBP said consideration will be given to any written comments received by Feb. 19 before taking this action. In addition, any party who has received a ruling or decision on the merchandise that is subject to the proposed revocations or modifications, or any party involved with a substantially identical transaction, should advise CBP by the date that written comments on the proposed ruling are due. (An importer's failure to advise CBP of such rulings, decisions, or substantially identical transactions may raise issues of reasonable care on the part of the importer or its agents for importations subsequent to the effective date of the final decision in this notice.)
Proposals
CBP is proposing to revoke or modify the rulings below, and any rulings on these products that may exist but have not been specifically identified. CBP is also proposing to revoke any treatment it has previously accorded to substantially identical transactions.
Clutch Master Cylinders and Clutch Slave Cylinders
| Item: A clutch master cylinder and a clutch slave cylinder for a motor vehicle hydraulic clutch system. The primary function of the clutch master cylinder is to generate hydraulic pressure within the clutch system. The clutch slave cylinder converts hydraulic pressure generated by the clutch master cylinder into the mechanical energy that is ultimately used to move the clutch pressure plate. |
| Current: 8708.93.75, 2.5%, (Parts and accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories: Clutches and parts thereof: For other vehicles: Other) |
| Proposed: Clutch master cylinder: 8413.50.00, free, (Pumps for liquids, whether or not fitted with a measuring device; liquid elevators; part thereof: Other reciprocating positive displacement pumps); Clutch slave cylinder: 8412.21.00, free, (Other engines and motors, and parts thereof: Hydraulic power engines and motors: Linear acting (cylinders).) |
| Reason: A subpart of a particular automotive part may only be classified under heading 8708 as parts for motor vehicles if the subpart is not more specifically described elsewhere in the tariff schedule. |
| Proposed for revocation: NY A86849 (1996), NY A85456 (1996) |
| Proposed new ruling: HQ H195876 |
Parts of Automotive Differential Assemblies
| Item: Various parts of motor vehicle front differential and rear differential assemblies, which allow the tires of a vehicle to spin at different speeds when making turns. |
| Current: 8708.99.68, 2.5%, (Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other parts for power trains) |
| Proposed: 8708.50.89, 2.5%, (Parts and accessories of the motor vehicles of headings 8701 to 8705: Drive-axels with differential, whether or not provided with other transmission components, and non-driving axles; parts thereof: Parts: For vehicles of heading 8703: Other: Other: Other) |
| Reason: New six-digit subheadings for differential parts were added to the HTS in 2007 as part of that year's World Customs Organization amendments to the Harmonized System. The parts of front and rear differential assemblies at issue in these rulings fall under that subheading. |
| Proposed for revocation: NY N009213 (2007), NY N009215 (2007), NY N186430 (2011), NY N186432 (2011) |
| Proposed new ruling: HQ H191698 |