CLA-2 CO:R:C:M 089805 MBR
Mr. Michael J. Gambuzza
Zoom Telephonics, Inc.
207 South Street
Boston, MA 02111
RE: "Alternating Current Converter"; Static Converter; AC
Adapter
Dear Mr. Gambuzza:
Your letter of May 22, 1991, on behalf of Zoom Telephonics,
Inc., has been forwarded for our reply. You requested
classification of the "Alternating Current Converter," under the
Harmonized Tariff Schedule of the United States Annotated
(HTSUSA).
FACTS:
The subject merchandise is described as an "Alternating
Current Converter" AC adapter (static converter) used to convert
electrical energy in order to adapt it for further use.
ISSUE:
What is the proper classification of the "Alternating
Current Converter" (AC Adapter) static converter, under the
HTSUSA?
LAW AND ANALYSIS:
Classification of merchandise under the HTSUSA is in
accordance with the General Rules of Interpretation (GRI's),
taken in order. GRI 1 provides that classification is determined
according to the terms of the headings and any relative chapter
or section notes.
Subheading 8504.40.00, HTSUSA, provides for: "[e]lectrical
transformers, static converters (for example, rectifiers) and
inductors: [s]tatic converters."
The Harmonized Commodity Description and Coding System
Explanatory Notes (ENs) to heading 8504, HTSUSA, provides the
-2-
following guidance regarding static converters:
(II) Electrical Static Converters
The apparatus of this group are used to convert
electrical energy in order to adapt it for further use.
They incorporate converting elements (e.g., valves) of
different types. They may also incorporate various
auxiliary devices (e.g., transformers, induction coils,
resistors, command regulators, etc.). Their operation is
based on the principle that the converting elements act
alternately as conductors and non-conductors.
The fact that these apparatus often incorporate
auxiliary circuits to regulate the voltage of the emerging
current does not affect their classification in this group,
nor does the fact that they are sometimes referred to as
voltage or current regulators.
This group includes:
(C) Alternating current converters and cycle converters by
which alternating current (single or polyphase) is
converted to a different frequency or voltage.
The instant merchandise is clearly used to convert
electrical energy in order to adapt it for further use, and falls
squarely within the EN's delineation of static converters. Thus,
although the instant merchandise contains a transformer, the AC
Adapter contains many other components as well and, pursuant to
GRI 3(b), is classifiable under subheading 8504.40.00, HTSUSA,
which provides for: "[e]lectrical transformers, static converters
(for example, rectifiers) and inductors: [s]tatic converters."
HOLDING:
The "Alternating Current Converter" (AC Adapter) static
converter, is classifiable in subheading 8504.40.00, HTSUSA,
which provides for: "[e]lectrical transformers, static converters
(for example, rectifiers) and inductors: [s]tatic converters."
Sincerely,
John Durant, Director
Commercial Rulings Division