CLA-2 CO:R:C:M 088496 MBR

Ms. Deborah J. Clune
PBB Customs Consultants
P.O.Box 950
Buffalo, NY 14213

RE: Coaxial Security System Sensor Cables

Dear Ms. Clune:

This is in reply to your letter of November 12, 1990, on behalf of Senstar Corporation, requesting classification of coaxial security system sensor cables, imported from Canada, under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA).


The Sentrax "leaky" or ported coaxial sensor cable is designed to function as the detection element of an intrusion detection system for security applications.

The coaxial sensor cable is constructed of a solid copper center (conductor), surrounded by a layer of white polyethylene foam (insulator), which is enclosed in copper braid having open apertures (to allow leakage of electromagnetic field), all of which is encased in an outer jacket of black polyethylene.

A pair of these coaxial sensor cables are normally buried in the soil approximately nine inches deep and five feet apart around the perimeter to be protected. A radio frequency (RF) signal is transmitted into one of the cables, from an electronic transceiver module. A controlled amount of this RF signal leaks out of the apertures in the copper braid and thereby establishes an external electromagnetic field. Part of this energy passes back into the other parallel cable through its ports. When an intruder disturbs the electromagnetic field, a microcomputer in the receiver assesses the signal changes and compares them to predetermined thresholds. If the threshold is exceeded, then an alarm is generated by means of a relay closure or other signal. -2-


What is the classification of coaxial security system sensor cables, under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA)?


The General Rules of Interpretation (GRI's) to the HTSUSA govern the classification of goods in the tariff schedule. GRI 1 states, in pertinent part:

...classification shall be determined according to the terms of the headings and any relative section or chapter notes...

The coaxial sensor cables are prima facie classifiable under the following headings:

8544 Insulated (including enameled or anodized) wire, cable (including coaxial cable) and other insulated electric conductors, whether or not fitted with connectors:

8544.20.00 Coaxial cable and other coaxial electric conductors

* * * * * * * * * * * * *

8531 Electric sound or visual signaling apparatus (for example, bells, sirens, indicator panels, burglar or fire alarms), other than those of heading 8512 or 8513; parts thereof:

8531.90.00 Parts

The Harmonized Commodity Description and Coding System Explanatory Notes (EN), to heading 8544, page 1403, state:

Provided they are insulated, this heading covers electric wire, cable and other conductors (e.g., braids, strip, bars) used as conductors in electrical machinery, apparatus or installations. Subject to this condition, the heading includes wiring for interior work or for exterior use (e.g., underground, submarine or aerial wires or cables). These goods vary from very fine insulated wire to thick cables of more complex types.

The goods of this heading are made up of the following elements:

(A) A conductor - this may be single strand or multiple, and may be wholly of one metal or of different metals.

(B) One or more coverings of insulating material - the aim -3-

of these coverings is to prevent leakage of electric current from the conductor, and to protect it against damage....

(C) In certain cases a metal sheath (e.g., lead, brass, aluminum or steel); this serves as...a supplementary conductor in certain co-axial cables.

(D) Sometimes a metal armoring....

The Explanatory Notes, although not dispositive, should be looked to for the proper interpretation of the HTSUSA. See 54 Fed. Reg. 35128 (August 23, 1989).

These coaxial sensor cables are, in fact, insulated cable used as a conductor. In the instant case, the insulation is designed to prevent leakage, even though it is also designed to allow a controlled amount of leakage. Thus, without the insulating material in the instant merchandise, uncontrolled, excessive leakage would occur, vitiating the usefulness of the coaxial sensor cable. Thus, the fact remains that these coaxial sensor cables are insulated. Finally, they have a metal braid sheath which serves as a supplemental conductor.

Webster's New World Dictionary, Third College Edition, (1988), defines coaxial as: 3 "designating a high-frequency transmission line or cable in which a solid or stranded central conductor is surrounded by an insulating medium which, in turn, is surrounded by a solid or braided outside conductor in the form of a cylindrical shell: it is used for sending telephone, telegraph, television, etc. impulses."

Clearly, the instant sensor cable is a "coaxial cable" since it consists of a solid copper center (conductor), surrounded by polyethylene (insulating medium), which, in turn, is surrounded by copper braid (outside conductor), and is used for sending or receiving RF impulses.

The McGraw-Hill Encyclopedia of Science & Technology, Vol. 4, (1987), states that: "Coaxial units are designed for different mechanical behavior depending upon the application." The subject coaxial sensor cables are designed for a very specific application. However, they are still properly described and classifiable under the provision for coaxial cables.

The Section XVI, Legal Notes provide direction here:

2. Subject to note 1 to this section, note 1 to chapter 84 and to note 1 to chapter 85, parts of machines (not being parts of the articles of heading 8484, 8544, 8546, or 8547) are to be classified according to the following rules: -4-

(a) Parts which are goods included in any of the headings of chapters 84 and 85 (other than headings 8485 and 8548) are in all cases to be classified in their respective headings.

Therefore, since the coaxial sensor cables are goods included in heading 8544, HTSUSA, they are properly classifiable in that heading.


The Sentrax "leaky" or ported coaxial sensor cable is classifiable under subheading 8544.20.00, HTSUSA, which provides for: "Insulated (including enameled or anodized) wire, cable (including coaxial cable) and other insulated electric conductors, whether or not fitted with connectors: Coaxial cable and other coaxial electric conductors." The rate of duty is 3.7% ad valorem, if the requirements of the U.S.-Canada Free Trade Agreement are met.


John Durant, Director
Commercial Rulings Division