CLA-2 CO:R:C:G 087499 CMS
9027.90.40
9030.39.00
8537.10.00
Doug Lenhart, Ph.D.
Vice President of Marketing
Cypress Systems, Inc.
P.O. Box 3931
Lawrence, Kansas 66046
RE: Potentiostat; Galvanostat; Rotating Ring and Disc
Electrode; Tachyprocesseur Speed Control Unit; Instruments
For Electrochemical Analysis; Electrochemistry
Dear Dr. Lenhart,
Your request dated June 5, 1990, for a classification ruling
on certain electrochemical analysis equipment has been forwarded
by the Regional Commissioner of Customs, New York to Customs
Headquarters for a reply. Our ruling follows.
FACTS:
The merchandise consists of certain components manufactured
by Tacussel Electronique for use in electrochemical analysis.
The components are the PJT 24-1 Potentiostat/Galvanostat, PJT 35-
2 AC/DC Potentiostat/Galvanostat, BIPAD Bipotentiostat/
Galvanostat, EAD-10000 Rotating Ring and Disc Electrode (RRDE),
and Tachyprocesseur Speed Control Unit for the RRDE. The
components may or may not be entered together.
The PJT 24-1 unit is a potentiostat/galvanostat which is
used to analyze materials by measuring the chemical response to
electrical stimulation. The unit has three jacks for electrodes
(not included) which are immersed in a solution in which the
materials being analyzed, such as metals or metal salts, are
dissolved. The unit provides a continuous measurement of the
working electrode potential. The imposed signal is adjustable
between +/- 5V or between +/- 10V if coupled with a signal
generator (e.g., the Tacussel IMT1, see HQ Ruling 087498).
The PJT 35-2 AC/DC unit is a potentiostat/galvanostat with
-2-
two built in adjustable voltage sources and an ohmic drop
compensation device. Like the PJT 24-1, the unit uses electrodes
(not included) to measure the chemical response to electrical
stimulation; the unit's imposed voltage range can also be
extended if coupled to a signal generator.
The BIPAD unit is a potentiostat/galvanostat with two
potentiostats with independent feedback loops. The unit controls
the potentials of two working electrodes versus the same
reference electrode. It is mainly designed for rotating ring and
disc electrode experiments (e.g., monitoring of intermediate
compounds and kinetic investigations). Currents can be read on
two analog zero-centre meters. Like the PJT 24-1 the unit
measures the chemical response to electrical stimulation.
The EAD-10000 Rotating Ring and Disc Electrode (RRDE) is
used with the BIPAD Bipotentiostat/Galvanostat. The electrode is
equipped with a servo-controlled and variable speed motor which
drives the rotating stem part of the electrode between 100 and
10000 rpm. The standard disc and ring electrode models are made
of platinum.
The Tachyprocesseur-Speed Control Unit controls the rotation
speed of the RRDE. The rotation speed is displayed on a LCD.
The importer states that the imported components are
intended to be used in the study of the corrosion of metals.
Other uses include analyzing the charge and purity of materials
and the rate of reaction.
ISSUE:
1. Are the PJT 24-1, PJT 35-2, BIPAD and EAD-10000 units
classified as instruments and apparatus for physical or chemical
analysis in Heading 9027, or as instruments and apparatus for
measuring or checking electrical quantities in Heading 9030?
2. Is the Tachyprocesseur unit classified as a control
panel or control base in Heading 8537, or as an instrument and
apparatus for physical or chemical analysis in Heading 9027?
LAW AND ANALYSIS:
Heading 9030 in pertinent part describes instruments and
apparatus for measuring or checking electrical quantities.
Heading 9027 in pertinent part provides for instruments and
apparatus for physical or chemical analysis. The features of the
potentiostat/galvanostats under consideration, including their
amperage ranges, make them suitable for testing materials, such
as metals and metal salts, by measuring the chemical responses to
electrical stimulation. These components are designed to
function in a system which performs electrochemical analysis.
-3-
They are used in the measuring of electrical quantities, but do
this principally to perform physical or chemical analysis. The
potentionstat/galvanostats are more specifically described by
Heading 9027 and are classified in 9027.80.40, HTSUSA.
Like the potentiostat/galvanostats, the RRDE's are
principally used for electrochemical analysis. When entered
separately the RRDE's are classified as parts of instruments or
apparatus for physical or chemical analysis in 9027.90.40,
HTSUSA. When entered with the potentiostat/galvanostats with
which they function the RRDE's are classified with those
components as functional units in 9027.80.40, HTSUSA.
The Tachyprocesseur units are principally used to control
the rotation speed of the RRDE's. When entered separately from
the electrodes they control they are classified as control panels
or control bases in 8537.10.00. When entered with the electrodes
they are classified with the electrodes as functional units in
9027.80.40, HTSUSA.
HOLDING:
The PJT 24-1 Potentiostat/Galvanostat, PJT 35-2 AC/DC
Potentiostat/Galvanostat and BIPAD Bipotentiostat/Galvanostat are
classified as instruments and apparatus for physical or chemical
analysis in 9027.80.40, HTSUSA.
The EAD-10000 Rotating Ring and Disc Electrodes entered
separately are classified as parts of instruments and apparatus
for physical or chemical analysis in 9027.90.40, HTSUSA. When
entered with potentiostat/galvanostats or speed control units
with which they function the RRDE's are classified with those
components as functional units in 9027.80.40, HTSUSA.
The Tachyprocesseur Speed Control Units entered separately
are classified as a control panels or control bases in
8537.10.00, HTSUSA. When entered with the electrodes they
control the Units are classified with the electrodes as
functional units in 9027.80.40, HTSUSA.
Sincerely,
John Durant, Director
Commercial Rulings Division