CLA-2 CO:R:C:G 088063 JMH
Mr. Thomas C. Lloyd
Customs Administrator
3M Logistics
P.O. Box 33800
St. Paul, MN 55133-3800
RE: Charge-Guard Adjustable Wrist Strap; electrical apparatus
for protecting electrical circuits
Dear Mr. LLoyd:
Your September 10, 1990 request for a classification ruling
regarding the 2200 series Charge-Guard Adjustable Wrist Strap
imported from Mexico has been forwarded to this office for a
reply.
FACTS:
The articles in question are the 2200 series Charge-Guard
Adjustable Wrist Strap which are imported from Mexico. The wrist
strap consists of a wrist band, a coil cord, and a banana plug or
an alligator clip. The wrist band is made of knitted polyester
with spandex and a silver plated nylon thread. The wrist band
has a plastic/metal snap for attachment to the cord. The metal
base of the snap lies flat on the wearer's wrist. A 1-megohm
resistor is molded into the snap. The cord is made of a single
bundle of tinsel conductor laced into high strength, synthetic
fibers. The snap fastener is on one end of the cord. The other
end of the cord has a banana plug or alligator clip that
attaches to a conductive table or floor mat to "ground" any
static charge flowing through the cord and strap.
The Wrist Strap is used for safety purposes to protect the
wearer from inadvertently coming into contact with up to 240
volts. However, typically the Wrist Strap is used by repair
technicians to protect printed circuit boards and static
sensitive electronic devices from static charges. The Wrist
Strap "grounds" the technician repairing the electronic device
from any static charge that would otherwise occur.
-2-
ISSUE:
What is the appropriate classification for the 2200 series
Charge-Guard Adjustable Wrist Strap.
LAW AND ANALYSIS:
The classification of merchandise under the Harmonized
Tariff Schedule of the United States Annotated ("HTSUSA") is
governed by the General Rules of Interpretation ("GRIs"). GRI 1,
HTSUSA, states in part that "for legal purposes, classification
shall be determined according to the terms of the headings and
any relative section or chapter notes..."
The Wrist Strap acts to collect static charges that could
damage printed circuit boards and then disperses the charge to
ground. The Wrist Strap protects printed circuit boards and
other electrical apparatus from damaging current. By its
operation the Wrist Strap meets the terms of heading 8536,
HTSUSA, as an electrical apparatus that protects electrical
circuits. The proper classification for the Charge-Guard
Adjustable Wrist Strap is subheading 8536.30.00, HTSUSA, as
"Electrical apparatus for...protecting electrical circuits...for
a voltage not exceeding 1,000 V...Other apparatus for protecting
electrical circuits..."
HOLDING:
The Charge-Guard Adjustable Wrist Strap protects electrical
apparatus from damage caused by static electricity and other
stray current. In accordance with GRI 1, the Wrist Strap meets
the terms of heading 8536. The proper classification for the
Charge-Guard Adjustable Wrist Strap is subheading 8536.30.00,
HTSUSA, as "Electrical apparatus for...protecting electrical
circuits...for a voltage not exceeding 1,000 V...Other apparatus
for protecting electrical circuits..."
Sincerely,
John Durant, Director
Commercial Rulings Division