Sept. 13 CBP Bulletin Proposes to Revoke Ruling on Car Cleaner and Modify Ruling on Energy Absorbers
In the Sept. 13 Customs Bulletin (Vol. 57, No. 33), CBP published a proposal to revoke a ruling letter concerning a car cleaner and modify another concerning bumper energy absorbers.
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Comments on Proposals Due Oct. 13
CBP said consideration will be given to any written comments received by Oct. 13 before taking these actions. In addition, any party that 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 after the effective date of the final decision in this notice.)
Proposal
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 also is proposing to revoke any treatment it has previously accorded to substantially identical transactions.
Car Cleaner
| Item: A plastic handle and three interchangeable components; a plastic ice scraper, a foam squeegee with rubber blade, and a bristle brush. Each component may be separately secured to the handle and may be detached by pressing the handle “clip.” |
| Current: 9603.90.8050, 5.6%, "Brooms, brushes (including brushes constituting parts of machines, appliances or vehicles), hand-operated mechanical floor sweepers, not motorized, mops and feather dusters; prepared knots and tufts for broom or brush making; paint pads and rollers; squeegees (other than roller squeegees)." |
| Proposed: 8708.99.81, 2.5%, “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other.” |
| Reason: The 3-in-1 Car Cleaner contributes to the effectiveness and affects the operations of motor vehicles of headings 8701 to 8705 by enabling the removal of ice or snow from their windows, lights, and other parts for better visibility while driving. The item appears identifiably suitable for use solely or principally for a motor vehicle. |
| Proposed for modification: HQ 952654, dated Jan. 27, 1993 |
| Proposed new ruling: HQ H313099 |
Bumper Energy Absorbers
| Items: (1) Bumper energy absorbers are designed to absorb impact in case of a collision, while effectively protecting other components, thus preventing more serious injuries and physical damage to the vehicle’s structure. (2) Bumper extensions function, which function as a shield of protection to the bumper, which can get easily scratched or chipped when exposed to harsh road elements. (3) Bumper reinforcements designed to reinforce the bumper assembly by fortifying and shielding the bumper from severe damage. |
| (1), (2), (3), 8708.29.5060, 2.5%, “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories of bodies (including cabs): Other: Other: Other.” |
| Proposed: 8708.10.60, 2.5%, “Parts and accessories of the motor vehicles of headings 8701 to 8705: Bumpers and parts thereof: Parts of bumpers.” |
| Reason: The energy absorbers, bumper extensions, and bumper reinforcements absorb impact and provide rigidity and protection to the bumper, which are integral to the function of motor vehicle bumpers. |
| Proposed for modification: NY N302213, dated Feb. 14, 2019 |
| Proposed new ruling: HQ H323227 |