CLA-2-85:RR:NC:MM:109 L81088

Mr. Lawrence M. Friedman
Barnes, Richardson & Colburn
475 Park Avenue South
New York, NY 10016

RE: The tariff classification of a three-phase AC motor controller from China

Dear Ms. Friedman:

In your letter dated November 24, 2004, you requested a tariff classification ruling on behalf of Electrolux Home Products.

The merchandise subject to this ruling is identified within your letter as a three-phase AC motor controller. It consists of a populated printed circuit board, which is attached to a metal heat sink and is fully enclosed within a plastic housing. The main function of the AC motor controller, also called an AC motor drive, is to manage motor movement in a washing machine using electrical energy. The function of the motor drive is to adapt the single-phase input line voltage into a three-phase output with the suitable voltage and frequency to run the motor at the desired speed. The nominal input voltage is 115 Vac (single-phase; the nominal line frequency is 60 Hz; the maximum output power is 800W; and the output speed range is 200 to 1700 rpm.). The AC motor controller does not have any user/interface operable controls, such as a touchpad or keypad. Therefore, it is not programmable by the user. Also, it does not contain terminals for an electrical connection.

The applicable subheading for the three-phase AC motor controller will be 8504.40.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Static converters: Speed drive controllers for electric motors.” The rate of duty will be 1.5 percent ad valorem.

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 Linda M. Hackett at 646-733-3015.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division