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RE: The tariff classification of a display module from Taiwan and a full display mirror from Canada
U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364977 September 22, 2026 CLA-2-85:OT:RR:NC:CEE007:N2; 208 CATEGORY: Classification TARIFF NO.: 8524.91.9000; 8528.59.2500 Dennis Wendling Gentex Corporation 600 N. Centennial St. Zeeland Charter Township, MI 49464-1346 RE: The tariff classification of a display module from Taiwan and a full display mirror from Canada Dear Mr. Wendling: In your letter dated September 9, 2026, you requested a tariff classification ruling. The merchandise under consideration is a Gentex display module, part number 202-0103-000, and a full display mirror, part number 905-6694-006KT. The display module, part number 202-0103-000, is a 9.6-inch thin film transistor (TFT) liquid crystal display (LCD) module that is incorporated into the Gentex Display Mirror after importation. At the time of importation, this display module does not contain any video converting components, cannot process a video signal, and does not have a touchscreen. The full display mirror, part number 905-6694-006KT, is a composite good consisting of a rear-view mirror, a monitor, and a radio frequency controller mounted to a vehicle’s windscreen. It is a rear-view mirror with a monitor that features electrochromic automatic glare reduction, a display that receives, converts, and displays a video signal from a rear-facing camera, and a subsidiary radio frequency controller function that can be used as a garage door or gate opener. Moreover, it has a toggle feature that allows drivers to easily choose between mirror mode and display mode. The video display can be used exclusively for rearward vision, and the mirror function can be bypassed altogether. Accordingly, it is the opinion of this office that the essential character of the full display mirror is imparted by the monitor function. The applicable subheading for the display module, part number 202-0103-000 will be 8524.91.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Flat panel display modules, whether or not incorporating touch-sensitive screens: Other: Of liquid crystals: Other.” The rate of duty will be 4.5 percent. The applicable subheading for the full display mirror, part number 905-6694-006KT is 8528.59.2500, HTSUS, which provides for Monitors and projectors, not incorporating television reception apparatus; reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound or video recording or reproducing apparatus: Other monitors: Other: Color: With a flat panel screen: Other: With a video display diagonal not exceeding 34.29 cm. The rate of duty will be Free. The duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Lisa Cariello at lisa.a.cariello@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division
set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Lisa Cariello at lisa.a.cariello@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division