CLA-2-85:OT:RR:NC:N1:112

Ms. Valerie H. Holtrop
Worldwide Logistic Solutions Inc.
18 Golden Wheat Lane
Wrightstown, WI 54180

RE: The tariff classification of compact actuators, sidestick controllers, and system power supply from Germany

Dear Ms. Holtrop:

In your letter dated July 11, 2011, you requested a tariff classification ruling on behalf of your client Wittenstein Arena Inc.

The four items concerned are two Compact Actuators (part numbers MDTC004 and MYTC010), Sidestick Controllers, and System Power Supply (SPS). The first item is the MDTC004 Compact Actuator which is the smallest actuator available for control loading. It is used for flight simulators and other applications, located on axis close to controls. This actuator consists of an electric motor, a separate modular control loading electronics, a flange mounted torque sensor, and a variety of gear ratios to provide a range of torques up to 60 Nm to meet the needs of the application. The MDTC004 Compact Actuator can be used for sidesticks, throttles and tiller axes as an example. The electric motor used in this actuator is a 28 Volt brushless, DC motor that generates 400 Watts.

The second item is the control loading MYTC010 Compact Actuator which can be provided in an inline or L-shaped version to meet the space envelope needs as well as being close to the controls. This actuator is used for flight simulators and other applications. It has an electric motor, integrated modular control loading electronics and an output flange mounted torque sensor. The concept is based on industrial motor and gearbox technology and has been adapted for the simulation industry to provide the smoothest of feels. With the variety of gear ratios it is possible to provide a range of torques up to 180 Nm to meet the needs of the application. The actuator can be used for cyclic, collective and centerstick pitch axes as an example. The electric motor used in this actuator is a 28 or 48 Volt brushless, DC motor that generates 330 Watts.

The third item is the Sidestick Controllers which has integrated motors, gearboxes, control loading electronics and force sensor technology. The features of this system include independent pitch and roll axes with high fidelity brushless DC motors with integrated control electronics. It has compact configuration and it is easily mountable with bolt down fixing to the cockpit frame. The Sidestick Controllers can bus interface for actuator control from the SCM and has built-in force sensor and a realistic grip with full switch fidelity and functionality (optional).

The fourth item is the System Power Supply (SPS) which consists of an off the shelf industrial chassis fitted with a power supplies, circuit breakers and electronics in order to provide the System Control Module (SCM) system with the necessary power. It converts 85 to 264 VAC (Volts Alternating Current) to 28 VDC (Volts Direct Current) providing an output of 500 Watts.

The applicable subheading for the compact actuators will be 8501.31.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Electric motors…: Other DC motors;…: Of an output not exceeding 750 W: Motors: Exceeding 74.6 W but not exceeding 735 W". The rate of duty will be 4%.

The applicable subheading for the Sidestick Controllers will be 8537.10.9070, 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 heading 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Other." The general rate of duty will be 2.7 percent ad valorem.

The applicable subheading for the System Power Supply (SPS) will be 8504.40.9530, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Static converters: Other: Rectifiers and rectifying apparatus: Power supplies: With a power output exceeding 150W but not exceeding 500W." The rate of duty will be 1.5 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 Steven Pollichino at (646) 733-3008.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division