CLA-2 CO:R:C:M 953074 MBR

Mr. Sal Della Ventura
Sony Corporation of America
1 Sony Drive
Park Ridge, New Jersey 07656-8003

RE: Ferrite Core; Sony Corporation of America; Insulating Fittings For Electrical Machines; HQ 950417; HQ 089042; HQ 089263; HQ 089869; HQ 082097; "Insulate" Defined; Principal Use

Dear Mr. Della Ventura:

This is in reply to your letter of November 17, 1992, on behalf of the Sony Corporation of America, requesting classification of "ferrite cores," under the Harmonized Tariff Schedule of the United States (HTSUS).


Ferrites are ceramic materials which exhibit a high degree of magnetic sensitivity. Ferrite material is manufactured by combining certain metallic oxides with a binding agent under high temperature and pressure.

Because of their high electrical resistivity and magnetic permeability, magnetically soft ferrites are particularly well suited for the storage, transmission, or reception of magnetic energy. The resistivity of ferrite material also allows those materials to be used in the conversion of electric energy into magnetic energy and vice versa via induction. Because of these capabilities, ferrite material is commonly used in computer memories and electrical components.

The instant ferrite core is in the shape of a donut measuring 3/4 inch in diameter. It has a rubber or plastic sleeve around it. You have stated that the instant ferrite cores are designed to be "slipped over certain electrical current carrying leads to choke out noise and/or distortion."



Is the donut shaped ferrite core an insulating fitting for electrical machines, classifiable in subheading 8547.10.80, under the Harmonized Tariff Schedule of the United States (HTSUS)?


The General Rules of Interpretation (GRI's) to the HTSUS 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...

Customs has addressed the classification of various ferrite apparatus under the HTSUS in HQ 950417, dated January 7, 1992, HQ 089042, dated July 26, 1991, HQ 089263, dated August 15, 1991, HQ 089869, dated October 16, 1991, and HQ 082097, dated March 14, 1989. Each of the prior rulings has dealt with ferrites that have an established principal use.

While the instant ferrite core may not be principally used with any machine in particular, it is principally used to "choke out noise and/or distortion" in electrical machines. The Webster's New World Dictionary, Third College Edition (1988) defines "insulate" as follows:

1 to set apart; detach from the rest; isolate 2 to separate or cover with a nonconducting material in order to prevent the passage or leakage of electricity, heat, sound, radioactive particles, etc.

The Harmonized Commodity Description and Coding System Explanatory Notes (ENs), regarding heading 8547, HTSUS, which provides for insulating fittings for electrical machines, page 1407, state:

With the exception of insulators as such (heading 85.46), this group covers all fittings for electrical machinery, appliances or apparatus, provided:

(i) They are wholly of insulating material, or are wholly of insulating material (e.g., plastics) apart from any minor components of metal (screws, threaded sockets, sleeves, etc.) incorporated during molding solely for purposes of assembly.

and (ii) They are designed for insulating purposes even though at the same time they have other functions (e.g., protection).


In general the fittings of this group are obtained by molding or casting, or by sawing, cutting or otherwise working the raw material. They may be drilled, threaded, filed, grooved, etc.

They may be made of any insulating material (e.g., glass, ceramics, steatite, hardened rubber, plastics, resin impregnated paper or paperboard, asbestos-cement or mica).

These fittings may be in various forms. This group includes, inter alia, covers, bases and other parts of switches, circuit breakers, etc.; bases and supports for fuses; rings and other parts for lamp holders; formers for resistors or coils; connection strips and dominoes not fitted with their terminals; cores for bobbins and windings of various kinds; spark plug bodies.

It is Customs position that the function of "choking out noise and/or distortion" is, in fact, an electrical insulation function because it functions to isolate the electrical connection leads from external electrical phenomena. Therefore, the instant ferrite cores do have a principal use, i.e., as an insulating fitting for electrical machines.

You have requested that we advise you whether the instant ferrite cores fall within the scope of anti-dumping case number A- 588-016. However, while U.S. Customs does provide classification rulings, anti-dumping scope reviews are conducted by the U.S. Department of Commerce.


The instant ferrite cores for choking out noise and distortion in electrical machinery connections are classifiable in subheading 8547.10.80, HTSUS, which provides for: "[i]nsulating fittings for electrical machines, appliances or equipment, being fittings wholly of insulating material apart from any minor components of metal (for example, threaded sockets) incorporated during molding solely for the purposes of assembly, other than insulators of heading 8546: [i]nsulating fittings of ceramics: [o]ther." The rate of duty is 6% ad valorem.


John Durant, Director