CATEGORY: Classification s325

NY R02779

November 30, 2005

CLA-2-90:RR:NC:N1:105 R02779

CATEGORY: Classification

TARIFF NO.: 9014.10.7060

Ms. Maria Cecilia Silva Superex Canada Limited 601 Gordon Baker Road Willowdale, Ontario M2N 7K2 Canada

RE: The tariff classification of a Digital Dashboard Compass from China

Dear Ms. Silva:

In your letter dated November 2, 2005, you requested a tariff classification ruling. No sample was submitted.

From the color image of the packaging, the item is called a “Digital Dashboard Compass” in large print and “with Clock, Calendar and Thermometer” in much smaller print. The display of compass information occupies more than half of the total space on the backlit LCD screen, which is designed to mount on an automobile dashboard.

Per the packaging, the compass has an arrow that moves in 22.5 degree increments and numeric headings that are shown in 5 degree increments and can be calibrated by driving the vehicle in a complete circle.

While you acknowledge that it is difficult to accurately breakdown costs on this kind of integrated device, the information from your supplier indicates that the cost of the compass function is more than 18 times the cost of any of the other 3.

New York Ruling Letter B84480-114, 5-15-97, classified an LCD compass/clock in HTS 9014.

We consider the compass portion to supply the essential character to this composite good. 2

Per the packaging, it uses “Magnetic Sensor Technology,” which is a magneto-inductive method from our information on that technology. Therefore, we take your item to be Electrical for the purposes of Additional U.S. Note 2 to HTS Chapter 90.

The applicable subheading for the Digital Dashboard Compass will be 9014.10.7060, Harmonized Tariff Schedule of the United States (HTS), which provides for “other,” electrical, direction finding compasses. The rate of duty will be free.

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 J. Sheridan at 646-733-3012.

Sincerely,

Robert B. Swierupski Director, National Commodity Specialist Division