CLA-2-73:OT:RR:NC:N1:113

Mr. George Rose
Addiran Global Group, Inc.
5508 Bentrose Drive
McKinney, TX 75070

RE: The tariff classification of pole gain bases from China

Dear Mr. Rose:

In your letter dated August 18, 2011, you requested a tariff classification ruling on imported pole gain bases. Photographs/drawings, product descriptions and specifications of the bases in question were submitted for our review. The merchandise under consideration is identified in your letter as “82070 pole gain bases”. You stated in your letter that the subject pole gain bases are “made of 64-45-12 ductile iron and galvanized…are assembled with a fiberglass rod and an endfitting, which provides a mounting medium for electrical equipment or insulators, and are then mounted to a power pole utilizing a thru bolt.” The pole gain bases are not imported with the fiberglass rod and the endfitting.

You indicated in your letter that “the 82070 gain base is affixed to the pole, it does not come in contact with an electric conductor. The products (equipment mounts and conductor supports) these pole gains are incorporated in do not provide any insulating properties…Additionally, the finished products (equipment mounts and conductor supports) simply provide a mounting medium. In the case of the conductor support, it provides a mounting medium, depending on style, for either a pin type insulator or a line post insulator. And in the case of the equipment mounts provide a mounting medium to mount electrical equipment (cutouts, terminators, arresters, etc.), which have their own insulating properties." You stated that you are requesting a classification ruling on the “82070 pole gain base only”.

The applicable subheading for the 82070 pole gain bases will be 7326.90.8588, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel, other, other, other, other, other. The rate of duty will be 2.9 percent ad valorem.

Duty rates 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 Ann Taub at (646) 733-3018.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division