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

Paula M. Connelly
Law Offices of Paula M. Connelly
12 Alfred St., Suite 300
Woburn, MA 01801

RE: The tariff classification of a printed circuit board assembly from Canada

Dear Ms. Connelly:

In your letter dated April 19, 2012, you requested a tariff classification ruling on behalf of your client, Pollak Switch Product Division of Stoneridge.

The item concerned is a printed circuit board assembly for a capacitive touch keypad. The board contains integrated circuits, transistors, diodes, varistors, LED’s, capacitors and resistors. After importation into the United States the board will be incorporated into an electronic keypad for a vehicular security system.

The keypad’s functionality is achieved by monitoring a capacitive charge between a series of electrodes on the printed circuit board. When the user touches the keypad, the capacitive field flux is disrupted. An on-board microprocessor monitors the capacitive charge values. When there is a change in value the microprocessor sends a signal to the transistors which then change the voltage state on three output lines. The voltage state on the output lines is interpreted by the vehicle’s body control module as a number pressed on the keypad. The capacitive touch pad provides the vehicle end user with the ability to unlock the vehicle by touching the keys corresponding to the vehicles’ security code.

The applicable subheading for the printed circuit board assembly will be 8543.90.6800, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Parts: Other: Printed circuit assemblies: Other”. The general rate of duty will be 2.6%.

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,

Thomas J. Russo
Director
National Commodity Specialist Division