CLA-2-85:OT:RR:NC:N1:109
Mr. Thomas J. O’Donnell
Rodriguez O’Donnell Gonzalez & Williams, P.C.
Attorneys & Counselors at Law
8430 West Bryn Mawr Ave, Suite 525
Chicago, IL 60631
RE: The tariff classification of Current Transformers from Germany
Dear Mr. O’Donnell:
In your letter dated May 11, 2010 you requested a tariff classification ruling on behalf of your client, Vacuumschmelze GmbH & Co.
The merchandise subject to this ruling is current transformers. They are identified within your letter as Model Nos. T60404-E4623-X002, T60404-E4625-X501, and T60404-E4628-X001. Current transformers are used for monitoring and/or precision measurement of current flowing in a “primary” conductor. In addition to the intended use by utility companies in watt-hour meters, these current transformers could also be used in other energy measurement applications such as sub metering of multifamily dwelling units, factory automation equipment metering, and monitoring data centers for building equipment control.
These current transformers function as current measuring devices in the following manner. Like any other transformer, current transformers function by means of a primary winding, a soft magnetic core, and a secondary winding. They are supplied in the general shape of a toroid and have an open middle section through which a customer supplied 1-turn primary winding conductor may be installed. The transformers are used to measure current and the current to be measured is called the primary current. The wire or conductive path carrying the primary current, i.e., the current to be measured, is passed through the center of the toroid. The soft magnetic core is a VAC CT toroid core based on VAC strip-wound core material. Wound around this toroid core is copper wire, which functions as the secondary winding. Model No. T60404-E4628-X001 has 1,000 turns, while Model Nos. T60404-E4623-X002 and T60404-E4625-X501 each have 2,500 turns for the secondary winding. The soft magnetic material in the toroid core captures magnetic flux associated with the primary current. By magnetic induction, that flux causes a proportional level of current to flow in the copper wire of the secondary winding.
The amount of current in the copper wire of the secondary is the primary current divided by the numbers of turns of copper wire. Thus, a high amperage current, i.e., 250A, that might be the sum of all currents being used in a residential dwelling is proportional to the primary-to-secondary turns ratio, i.e., 1:2500 in the case of the T60404-E4625-X501, and is transformed into a precisely proportional low level signal current, i.e., 250A/2500 turns = 100.0 mA, output that can be measured with signal-level grade integrated circuit electronics. The VAC CTs, thus, act as current measuring devices.
As discussed in headquarters’ ruling HQ 966872, current transformers have been found by Customs and the courts to be unrated.
The applicable subheading for the current transformers (Model Nos. T60404-E4623-X002, T60404-E4625-X501, and T60404-E4628-X001) will be 8504.31.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical transformers, static converters (for example, rectifiers) and inductors; parts thereof: Other transformers: Having a power handling capacity not exceeding 1 kVA: Unrated.” The rate of duty will be free.
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