CLA-2-85:OT:RR:NC:1:120
Ms. Stephanie Miller
ASA Electronics, LLC 2602 Marina Drive
Elkhart, IN 46514
RE: The tariff classification of a power control center from Taiwan.
Dear Ms. Miller: In your letter dated May 29, 2015 you requested a tariff classification ruling. The merchandise under consideration is identified as the JRVCS1 power control center, which is used to control and monitor specific systems within a recreational vehicle (RV) such as; door locks, interior/exterior lighting, generator, water heater, and camera surveillance, to name a few. This power control center is comprised of a display commander and a body control module which connect to each other through Bluetooth and Wi-Fi technology.
The body control module (bcm) is comprised of six switches, twenty-six sockets, four surge suppressors, and eighty terminal strips. It is designed to receive and transmit power from the output units (or systems) it controls via a 12 volt relay based on the commands of the user.
The display commander is comprised of a resistive LCD touchscreen and shows the status of the systems that it is controlling. It functions by touching the system one chooses to use and transmits a signal (or command) to the body control module to operate that system.
Based upon the information provided by you, both the body control module and the display commander are designed to function together as a system. They are shipped and sold together as a system and meet the definition of a functional unit pursuant to Section XVI, Note 4, of the Harmonized Tariff Schedule of the United States (HTSUS) which states: “where a machine (including a combination of machines) consists of individual components (whether separate or interconnected by piping, transmission devices, electric cables or by other devices) intended to contribute together to a clearly defined function covered by one or the headings in chapter 84 or chapter 85, then the whole falls to be classified in the heading appropriate to that function.”
The clearly defined function of this functional unit is that of controlling the RV systems.
The applicable subheading for the JRVCS1 power control center be 8537.10.9060, HTSUS, which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Programmable controllers.” The general rate of duty will be 2.7 percent ad valorem. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/. 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 Faingar at: [email protected]. Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division