CLA-2-85:RR:E:NC:N1:109

Ms. Jackie H. Kojian
International Trade Compliance Manager
PerkinElmer Optoelectronics
Worldwide Headquarters
44370 Christy Street
Fremont, CA 94538

RE: The tariff classification of a series injection triggering (Type A) transformer and external triggering (Type B) transformer from Malaysia

Dear Ms. Kojian:

In your letter dated February 14, 2007, you requested a tariff classification ruling on 53 various transformers. Each ruling request may contain a maximum of 5 items. Therefore, this ruling will determine the classification of 5 of the 53 transformers that you have requested a tariff classification ruling on.

The merchandise subject to this ruling is injection triggering (Type A) transformers and external triggering (Type B) transformers. These transformers are trigger coil pulse transformers for application in arc lamp applications. They are marketed as “trigger coils” because the process that effects the initial ionization within a flashlamp/arc lamp is known as “triggering”. Triggering creates a voltage gradient in the gas of sufficient magnitude to cause ionization of the lamps.

Injection triggering (Type A) transformers differs from external triggering (Type B) transformers in that the discharge current from the energy-storage-capacitor passes through the secondary winding of the trigger coil. The secondary winding of the trigger coil must therefore be designed to carry the total current of the discharge. This type of trigger coil is consequently larger, heavier and more expensive than the external trigger coil. Your series injection trigger (Type A) transformer TR-2144 and TR-2244 both have a power handling capacity of 44 kVA and your TS-136B has a power handling capacity of 1,650 kVA.

External triggering (Type B) transformers use a high voltage trigger pulse to create a thin ionized streamer between the anode and cathode within an arc lamp. The coupling of this voltage to the lamp may be accomplished using a thin nickel wire wrapped around the surface of the lamp envelope. These types of trigger coils are generally lighter, smaller and less expensive than those of injection triggering transformers. Your external triggering (Type B) transformer TR-130 has a power handling capacity of 1.3 kVA and your TR-132C has a power handling capacity of 24 kVA.

The applicable subheading for the external triggering (Type B) transformer TR-130 will be 8504.32.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical transformers: Other transformers: Having a power handling capacity exceeding 1 kVA but not exceeding 16 kVA.” The rate of duty will be 2.4 percent ad valorem.

The applicable subheading for the series injection triggering (Type A) transformer and TR-2144, TR-2244, and external triggering (Type B) transformer TR-132C will be 8504.33.0020, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical transformers: Other transformers: Having a power handling capacity exceeding 16 kVA but not exceeding 50 kVA.” The rate of duty will be 1.6 percent ad valorem.

The applicable subheading for the series injection triggering (Type A) transformer TS-136B will be 8504.34.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical transformers: Other transformers: Having a power handling capacity exceeding 500 kVA.” The rate of duty will be 1.6 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 Linda M. Hackett at 646-733-3015.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division