March 31, 2003
TARIFF NO.: 8450.90.6000; 8451.90.9010; 8516.90.8000; 3926.90.2500
Mr. Lawrence M. Friedman Barnes, Richardson & Colburn 303 East Wacker Drive Chicago, Illinois 60601
RE: The tariff classification of plastic knobs for various appliances from Taiwan
Dear Mr. Friedman:
In your letter dated March 3, 2003 on behalf of Electrolux Home Products, North America of Augusta, Georgia you requested a tariff classification ruling.
You have provided samples and drawings of plastic knobs which your client plans to import for use with its washers, dryers and stoves. They include:
Part number 1340445, a rotary control knob that is used to activate selector switches on a home laundry washing machine
Part number 1316524, a plastic timer knob assembly that is used to activate the timer on a home laundry dryer
Part number 3162230, a plastic temperature control knob used on electric stoves
Part number 3162200, a plastic temperature control knob used on gas stoves
All of the above knobs are made of plastic. The knobs contain negligible amounts of metal due to the insertion of metal spring clips or threaded metal within plastic shafts that fit into the knobs themselves and allow them to be affixed to timers and switches. The knobs are molded and shaped to EHP’s specifications. All of the above knobs are imprinted with an indicator line that allows the user to determine the temperature or timer setting.
You have suggested that the terms of the headings, section and chapter notes and the explanatory notes necessitate classification of these plastic knobs under the relevant parts provision for each appliance. You continue that all but one of the appliances in question are classified in chapters 84 and 85, with gas stoves of heading 7321 being the exception. You state that neither the Section XV notes nor chapter 73 notes preclude classification of plastic knobs within the parts provision of gas stoves.
You state further that treatment of plastic knobs within Customs has been somewhat inconsistent. NY rulings 859215 and 869235 classified plastic control knobs for gas grills and gas stoves under HTS subheading 3926.90.2500 while HQ ruling 082334 classified control knobs for refrigerators, washers and dryers as parts of those machines and HQ ruling 083984 classified control knobs for air conditioners as parts of air conditioning machines.
The rulings are not inconsistent. Heading 7321provides for stoves, ranges, … and similar non-electric domestic appliances, and parts thereof, of iron or steel. The terms of the heading preclude classification of plastic articles as parts hence the NY rulings were correct. The HQ rulings dealt with products of section XVI which does not exclude plastic articles by section or chapter note or the terms of any individual heading.
The applicable subheading for the rotary control knob, part number 1340445, will be 8450.90.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for other parts of household or laundry-type washing machines, including machines which both wash and dry. The rate of duty will be 2.6 percent.
The applicable subheading for the timer knob, part number 1316524, will be 8451.90.9010, HTS, which provides for other parts of machinery (other than machinery of heading 8450) for washing, cleaning, wringing, drying, … textile yarns, fabrics or made up textile articles. The rate of duty will be 3.5 percent.
The applicable subheading for the control knob for the electric stove, part number 3162230, will be 8516.90.8000, HTS, which provides for other parts for the cooking stoves, ranges and ovens of subheading 8516.60.40. The rate of duty will be free.
Finally, the applicable subheading for the control knob for the gas stove, part number 3162200, will be 3926.90.25, HTS, which provides for other articles of plastic: handles and knobs, not elsewhere specified or included, of plastics. The rate of duty will be 6.5 percent.
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 Robert Losche at 646-733-3011.
Robert B. Swierupski Director, National Commodity Specialist Division