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