CLA-2-85:OT:RR:NC:1:110

Mr. Jeffrey H. Bane
ABB, Inc.
29801 Euclid Ave.
Wickliffe, OH 44092

RE: The tariff classification of a controller from India.

Dear Mr. Bane:

In your letter dated April 1, 2011, you requested a tariff classification ruling.

The merchandise under consideration is the ABB Bridge Controller, Module BRC410. The information you provided with your ruling request indicates that the controller is a rack mounted controller designed to interface with ABB designed I/O devices in the Symphony Enterprise Management and Control System. The BRC410 is a standalone controller that can handle specific control and information processing applications in addition to multiple-loop analog, sequential and batch control processing applicators. This controller is designed for installation into the control panel of a process control system. The BRC410 is a printed circuit board assembly (PCBA) consisting of a single printed circuit board (PCB) and an Ethernet daughterboard mounted to a molded plastic faceplate with two latching screws, one at the top and one at the bottom. The latching screws are used to lock the controller into one slot of a module mounting unit (MMU) and a plug-in printed circuit board connector at the back of the assembly. On the front of the faceplate are sockets for an Ethernet Port and a multi-pin cable connector, 17 LED (light emitting diode) indicator lights and a combination Stop/Reset push-button switch. The PCBA has four eight-pole dipswitches, passive and active components including nonvolatile random access memory (NVRAM), static random access memory (DRAM), flash memory (ROM), a microprocessor, direct memory access (DMA) circuits, ABB custom bus circuits, redundancy circuits, and various support circuitry. The BRC410 memory is programmable by the customer to user defined functions via the serial port. This enables the controller to meet the control application requirements of supervisory control, optimization routines, performance assessment and process modeling.

The applicable subheading for the ABB Bridge Controller, Module BRC410, will be 8537.10.9060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 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 Thomas Campanelli at (646) 733-3016.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division