CLA-2-90:OT:RR:NC:1:104
Mr. Michael E. Carnahan
Renogy LLC
11959 Nicholson Drive
Suite 10201
Baton Rouge, LA 70810
RE: The tariff classification of Manufacturing Equipment of Solar Photovoltaic Panels from China
Dear Mr. Carnahan:
In your letter dated December 21, 2010 you requested a tariff classification ruling.
Your inquiry consists of specific manufacturing equipment for solar photovoltaic panels that are suitable for generating electricity for residential, commercial, and solar farm projects. The specific equipment you are requesting a classification on consists of 1) Frame Press, 2) Hipot Tester and 3) Sun Simulator.
The Hipot Tester covered by your submission is described as an electrical power supply and measurement device used to ensure product quality control by checking that electrical components are properly isolated and insulated, per their specifications. While you don’t provide specifics on the model hipot tester you will be importing, we presume it is similar in form and function to those described at this website, http://www.hipot.com/products/hipot-testers.aspx (which belongs to a manufacturer of hipot testers), in that they include a source of high voltage, a current meter, and a means of connecting the voltage source to the devices being tested. They therefore operate in a manner similar to that of the 5kV insulation tester described in New York Ruling Letter N011220, dated June 11, 2007.
The Sun Simulator is described as a large light box or chamber, measuring approximately 8 feet long by 9 feet wide by 16 feet tall, with a 1000 watt sun lamp installed on the interior. A finished solar panel is placed in the chamber, and the sun lamp is activated, radiating the solar panel. The solar panel converts the energy from the sun lamp into electricity (as it would with real sunlight) and specially designed equipment within the chamber measures and records the electrical power generated by the solar panel. The purpose of the sun simulator is to check that completed solar panels function within their specifications before being shipped out, serving as a quality control device. The measuring equipment within the sun simulator can be connected to a computer and printer for labeling and record keeping. The sun simulator does not appear to utilize any optical elements, as they are defined in Additional U.S. Note 3 to Chapter 90.
The applicable subheading for the Hipot Tester will be 9030.39.0100, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other instruments and appliances for measuring or checking voltage, current, resistance or power, with a recording device. The duty rate will be 1.7% ad valorem.
The applicable subheading for the Sun Simulator will be 9031.80.8085, HTSUS, which provides for “other” Measuring or checking instruments, appliances and machines, not specified or included elsewhere in HTS Chapter 90. The duty rate will be 1.7% 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/.
Your inquiry does not provide enough information for us to give a classification ruling on the Frame Press. Your request for a classification ruling should include detailed information as to the unit’s step-by-step method of operation. Include schematic and/or illustrations showing the unit’s specifications. Include pictures showing the panels before and after framing. What specific features dedicate this frame press to working on solar panels only? Include information on the construction of the solar panels themselves. How are the solar cells arranged? Do they include elements such as junction boxes, terminals and connectors for external wiring? Are these panels equipped with elements which supply power directly to an external load such as a motor? Do the panels contain diodes to control the direction of the current? When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.
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 Patricia O’Donnell at (646) 733-3011.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division