CLA-2-84:RR:NC:120: L82171

Mr. Jason M. Waite
Alston & Bird LLP
601 Pennsylvania Avenue, N.W.
North Building, 10th Floor
Washington, DC 20004-2601

RE: The tariff classification of water treatment components, WSA1686 and WSA2072 from China

Dear Mr. Waite:

In your letter dated December 22, 2004 you requested a tariff classification ruling on behalf of Access Business Group International LLC. This request covered four electronic assembly components designed for use with the Quixtar eSpring Water Treatment Systems (WTS). Two of which were ruled upon in NY L81842. Items WSA1686 and WSA2072 are considered in this ruling. The relevant samples are being returned to you as requested.

WSA1686 and WSA2072 consist of three printed circuit board assemblies with electronic display components (LEDs), microprocessors, digital logic chips, and various electronic components such as capacitors, resistors, diodes, transformers, and inductors. WSA 1686 and WSA2072 combine the above components in an assembly. According to Section XVl, note 2(a) the assemblies are not goods included in one of the headings of Chapter 84 or 85. Section XVl, note 2(b) classifies the items as part of the water treatment system in heading 8421.

In your letter, you suggested classification under stat suffix (80), however stat suffix (40) is more applicable as part of a water treatment system.

The applicable subheading for WSA1686 and WSA2072 will be 8421.99.0040, Harmonized Tariff Schedule of the United States (HTS), which provides for Filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Parts: Other: Other. The rate of duty will be free.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Denise M. Faingar at (646) 733-3010.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division