Mr. William H. Sherman
Northern Customs Services
P.O. Box 331
Lewiston, NY 14092
RE: The tariff classification and status under the North American Free Trade Agreement (NAFTA) of electrical insulators from Canada; Article 509
Dear Mr. Sherman:
In your letter dated August 19, 1999, on behalf of Prenco Progress & Engineering Corp., Ltd., Canada, you requested a ruling on the status of electrical insulators from Canada under the NAFTA.
Samples of electrical insulator boot assemblies of both two and three piece construction were submitted with your request. The insulator assemblies, also known as spark plug boots or nipples, are used in the assembly of ignition cable sets for use in various ignition systems in internal combustion engines. The insulators are placed over the connection between the spark plug and the ignition cable terminal. The operating voltages of the ignition system typically range from 15000 to 25000 volts, requiring the use of insulators to prevent voltage breakdown to surrounding areas. The shaft portion of the insulator is always made of a polybutylene plastic material. The end seal is always made of a silicone or kraton/silicone plastic material. The cable entry boot portion is made of either rubber or plastic elastomeric components, such as EPDM, silicone, santoprene or kraton. The elastomeric qualities of these materials allow a tight seal between the spark plug, the boot material and the ignition cable terminal.
The insulators are assembled in Canada from parts manufactured in Taiwan. In assembling the two piece insulator, sealant is applied to the end seal, and the end seal is attached to the shaft. The seal is rotated to provide for even application of adhesive. The end seal attachment is visually inspected. The adhesive is allowed to cure for four hours. A silicone dielectric grease is applied to the inner end seal wall. The assembly of the three-piece insulator is identical except for the additional step of attaching and aligning the cable entry boot to the shaft.
The applicable tariff provision for the electrical insulator boot assemblies will be 8546.90.0000, Harmonized Tariff Schedule of the United States Annotated (HTSUSA), which provides for electrical insulators of any material…other. The general rate of duty will be Free.
The insulator assemblies are made from components of Taiwanese origin. The plastic components are classifiable in subheading 3926.90.9880, HTSUSA. The rubber components are classifiable in subheading 4016.99.6050, HTSUSA. Since each of the non-originating materials used to make the insulators has satisfied the changes in tariff classification required under HTSUSA General Note 12(t)/85.149, the insulator assemblies will be entitled to a free rate of duty under the NAFTA upon compliance with all applicable laws, regulations, and agreements.
This ruling is being issued under the provisions of Part 181 of the Customs Regulations (19 C.F.R. 181).
This ruling letter is binding only as to the party to whom it is issued and may be relied on only by that party.
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 David Curran at 212-637-7049.
Robert B. Swierupski