CLA-2-85:OT:RR:NC:N1:109
Mr. Barry E. Stark
Asst. Corp. Import/Export Manager
Hitachi America, Ltd.
50 Prospect Avenue
Tarrytown, NY 10591
RE: The tariff classification of an IPM (Intelligent/Integrated Power Module), a Main PCB, a Roto PCB, a Power Source PCB, and a Driver PCB from Japan
Dear Mr. Stark:
In your letter dated December 18, 2011 you requested a tariff classification ruling.
The merchandise subject to this ruling is five components of a Hitachi Series SJ300 inverter/variable frequency drive. The names of each of the components are an IPM (Intelligent/Integrated Power Module), a Main PCB, a Roto PCB, a Power Source PCB, and a Driver PCB. A sample of the IPM, Main PCB, Roto PCB and Power Source PCB were furnished. A picture of the Driver PCB was furnished because a sample was not available. The four samples are being returned to you as per your request. The picture of the Driver PCB will remain with our file.
The IPM (Intelligent/Integrated Power Module) is a sealed electronic module containing a printed circuit board (PCB), insulated gate bi-polar transistors (IGBT output power transistors), diodes, resistors, gate driver circuits, current detection circuits and a temperature sensing circuit. The gate driver circuits amplify and shape pulses from other printed circuit assemblies in the inverter to make them suitable to drive the IGBT gate input. The current detection circuits monitor current flow through each IGBT and sends signals to the gate driver to shut off outputs if current exceeds defined levels. The temperature sensing circuit monitors temperature of all IGBTs and module as a whole. It sends a signal to the gate driver to shut off output if the temperature exceeds defined levels. The IPM controls the flow of power from the Hitachi Series SJ300 inverter to a motor, much like a valve controls the flow of water in a pipe. It consists of a molded plastic module with terminal pins to connect to the other inverter components.
The Main PCB consists of a printed circuit board (PCB) that has capacitors, diodes, transistors, resistors, terminal strips, connectors, integrated circuits, and zener diodes mounted upon it. As such, it is a printed circuit assembly, as defined within Additional U.S. Note 1 to Section XVI of the Harmonized Tariff Schedule of the United States (HTSUS). It coordinates communications between the various printed circuit assemblies in the Hitachi Series SJ300 inverter and integrates various internal functions including communications with a logic printed circuit assembly and delivery of commands to the power modules to control the output of the inverter, but it is the integrated circuit, which is a microcontroller, that acts as a main controller to regulate the flow of data between the Hitachi Series SJ300 inverter’s printed circuit assemblies.
The Roto PCB consists of a printed circuit board (PCB) that has capacitors, diodes, transistors, transformers, resistors, ferrite, terminal strips, connectors, integrated circuits, zener diodes, and metal oxide varistors mounted upon it. As such, it is a printed circuit assembly, as defined within Additional U.S. Note 1 to Section XVI of the Harmonized Tariff Schedule of the United States (HTSUS). However, the Roto PCB contains a portion of the necessary internal power supply circuits for the Hitachi Series SJ300 inverter and converts alternating current (AC) power into various levels of direct current (DC) required by the other internal circuits of the inverter. It is estimated to operate in the range of 25-500 watts. Although it is in the form of a printed circuit assembly, which would classified in subheading 8504.90 under the parts provision of heading 8504, the Roto PCB is classifiable within its respective subheading of 8504.40.95, which more specifically describes it, as a rectifying power supply in accordance with Note 2(a) to Section XVI and General Rule of Interpretation (GRI) 6.
The Power Source PCB consists of a printed circuit board (PCB) that has capacitors, diodes, transistors, transformers, resistors, ferrite, terminal strips, connectors, integrated circuits, zener diodes, and metal oxide varistors mounted upon it. As such, it is a printed circuit assembly, as defined within Additional U.S. Note 1 to Section XVI of the Harmonized Tariff Schedule of the United States (HTSUS). However, the Power Source PCB, which is virtually identical to the Roto PCB in terms of form and function, contains a portion of the necessary internal power supply circuits for the Hitachi Series SJ300 inverter. It converts AC power into various levels of DC voltage required by the other internal circuits of the inverter. It is estimated to operate in the range of 25-500 watts. Although it is in the form of a printed circuit assembly, which would be classified in subheading 8504.90 under the parts provision of heading 8504, the Power Source PCB is classifiable within its respective subheading of 8504.40.95, which more specifically describes it, as a rectifying power supply in accordance with Note 2(a) to Section XVI and General Rule of Interpretation (GRI) 6.
The Driver PCB consists of capacitors, diodes, resistors, terminal strips, connectors, integrated circuits and zener diodes mounted upon it. As such, it is a printed circuit assembly, as defined within Additional U.S. Note 1 to Section XVI of the Harmonized Tariff Schedule of the United States (HTSUS). It provides signals to the IGBTs to control their operation. The Driver PCB is exclusively for use in the Hitachi Series SJ300 inverter and is a required component thereof.
The applicable subheading for the Roto PCB and the Power Source PCB will be 8504.40.9530, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Electrical transformers, static converters (for example, rectifiers) and inductors; parts thereof: 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.
The applicable subheading for the IPM (Intelligent/Integrated Power Module) will be 8504.40.9580, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Electrical transformers, static converters (for example, rectifiers) and inductors; parts thereof: Static converters: Other: Other." The rate of duty will be 1.5 percent ad valorem.
The applicable subheading for the Main PCB and the Driver PCB will be 8504.90.6500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Electrical transformers, static converters (for example, rectifiers) and inductors; parts thereof: Parts: Other: Printed circuit assemblies: Of the goods of subheading 8504.40 or 8504.50 for telecommunications apparatus." 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,
Thomas J. Russo
Director
National Commodity Specialist Division