CLA-2 CO:R:C:G 087498 CMS
Doug Lenhart, Ph.D.
Vice President of Marketing
Cypress Systems, Inc.
P.O. Box 3931
Lawrence, Kansas 66046
RE: Potentiostat; Galvanostat; Signal Generator; Impedance
Analyzer; Programmable Interface; Instruments For
Electrochemical Analysis; Electrochemistry
Dear Dr. Lenhart:
Your June 5, 1990 request 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.
The merchandise consists of certain components manufactured
by Tacussel Electronique for use in electrochemical analysis.
The components are the VTM-200S Potentiostat/Galvanostat, IMT1
Programmable Interface, IMT1 Software, PIL101T Scanning
Generator, and Z-Computer/Impedance Analyzer. The components may
or may not be entered together.
The VTM-200S Potentiostat/Galvanostat is a potentiostat/
galvanostat with a built-in ramp signal generator. One panel on
the unit indicates the status of the instrument and the applied
voltage while a second panel displays the measured current in the
course of an experiment. The unit is connected to a cell with
platinum electrodes (not included) for the purpose of testing the
behavior of metals or metal salts in certain solutions.
The IMT1 Programmable Interface incorporates a programmable
signal generator and is designed to function with and control the
VTM-200S unit and other Tacussel potentiostat/galvanostats. The
IMT1 can be connected to a microcomputer provided it is fitted
with the appropriate serial port.
The IMT1 Software is designed for electrochemical analysis
and is capable of managing free potentials, stabilization
criteria and relative or absolute potential scales. The software
is in the form of floppy discs.
The PIL101T Scanning Generator generates single, double or
multi-scans at a controlled sweep rate. The signal voltage is
generated by means of a digital/analog converter. The converter
outputs a "staircase" shaped slope in steps of .25mV. A
proportional analog output is delivered. The PIL101T is
compatible with many potentiostat/galvanostats including all
Tacussel instruments. The unit can be connected to a
The Z-Computer/Impedance Analyzer is connected to a
microcomputer (not included) and performs measurement control in
potentiostatic or galvanostatic mode. The front panel of the
unit incorporates jacks for electrodes. The Z-Computer allows
sine, triangle and square wave voltage to be superimposed. With
special software the unit can perform cyclic voltammetry with a
maximum data acquisition rate of 1 Hz.
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.
Is the merchandise classified as electrical apparatus,
n.s.p.f. in Heading 8543, as instruments and apparatus for
physical or chemical analysis in Heading 9027, or as instruments
and apparatus for measuring or checking electrical quantities in
LAW AND ANALYSIS:
None of the components under consideration are described in
Chapter 85 except as electrical apparatus, n.s.p.f. in Heading
8543. If the articles are electrical articles for measuring or
checking electrical quantities, they would be more specifically
described by Heading 9030. If the articles measure or check
electrical quantities principally for conducting physical or
chemical analysis they would be most specifically described by
Heading 9027. Further, if the components are articles of Chapter
90 then they are excluded from Chapters 84 and 85 pursuant to
Section XVI Note 1(m).
The principal use of the VTM-200S Potentiostat/Galvanostat
is to measure electrical quantities for the purpose of conducting
electrochemical analysis. Its features, including its amperage
range, make it suitable for testing the behavior of metals and
metal salts in solutions and for other physical or chemical
analysis. It is designed to function with other components (e.g.
programmable interface) in a system which analyzes the chemical
response to electrical stimulation. The Explanatory Notes to
Heading 9027, pp. 1515-1516, describe apparatus which perform
similar functions (e.g., an apparatus that analyzes dissolved
metals in water by evaluating the current/resistance relationship
of electrodes immersed in the solution, para. 13; an apparatus
that determines the components of liquids, including traces of
metals, using electrodes and a control unit, para. 14; an
apparatus that evaluates a product by analyzing current passing
through a solution, para. 23). The principal use of the VTM-
200S unit is to conduct physical or chemical analysis and it is
classified in 9027.80.40, HTSUSA.
The IMT1 Programmable Interface is designed to function with
and control the VTM-200S unit and other Tacussel
potentiostat/galvanostats used for electrochemical analysis. The
IMT1 incorporates a signal generator. Subheading 8543.20.00
specifically describes signal generators. However, the IMT1 is
not a standard signal generator. The IMT1 combines interface,
signal generator and control functions for the purpose of working
in an electrochemical analysis system. The IMT1 is most
specifically described by Heading 9027. It is classified in
9027.80.40, HTSUSA. The PIL101T Scanning Generator is similarly
classified in 9027.80.40, HTSUSA.
The Z-Computer/Impedance Analyzer is not the type of freely
programmable data processing unit described by Heading 8471.
Its principal use is to perform measurement control in
potentiostatic or galvanostatic mode and to function with other
electrochemical analysis components. It is classified in
With the exception of the software, all the components are
individually classified in 9027.80.40, HTSUSA, and would also be
classified there if entered together.
Pursuant to Chapter 85 Note 6, the IMT1 Software in the form
of floppy discs is classified in 8524.90.40, HTSUSA, whether or
not it is entered with apparatus for which it is intended.
The VTM-200S Potentiostat/Galvanostat, IMT1 Programmable
Interface, PIL101T Scanning Generator and Z Computer/Impedance
Analyzer are classified as instruments and apparatus for physical
or chemical analysis, in 9027.80.40, HTSUSA. The IMT1 Software
in the form of magnetic floppy discs is classified in
John Durant, Director
Commercial Rulings Division