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

Mr. Brian Kavanaugh
Deringer Logistics Consulting Group
173 West Service Road
Champlain, NY 12919

RE: The tariff classification for parts of the Nacelle Uptower and Controller Cabinet Assembly made in China

Dear Mr. Kavanaugh:

In your letter dated July 16, 2012, you requested a tariff classification ruling on behalf of Northern Power Systems. Diagrams of the subject articles were submitted for our review.

You stated in your letter that you are requesting a classification ruling on wind tower components. The components included in this ruling request are parts of the Nacelle Uptower and Controller Cabinet Assembly. The subject articles are identified as the NW100/Panel-Upper Rear Control (Part #1002115), the Panel-Lower Rear (Part #1002116), the Plate-AC Filter Mounting (Part #1002125), the Plate-Power Converter Bed (Part #1002130) and the NAC002.01 Rearframe Weldment (Part #1001113). Each of the articles under consideration are made of steel and do not contain any electrical components at the time of importation.

The NW100/Panel-Upper Rear Control is a part of the controller cabinet and will hold the upper rear controls when it is installed. The panel measures approximately 1167 mm in width by 418 mm in height. The Panel-Lower Rear is a part of the controller cabinet and will hold the lower rear controls when it is installed. The panel measures approximately 1168 mm in width by 703 mm in height. The Plate-AC Filter Mounting allows the Air Conditioning Filter to be mounted to the controller cabinet. The mounting plate measures approximately 540 mm in width by 343 mm in height. The Plate-Power Converter Bed is a part of the controller cabinet. The converter bed plate measures approximately 672 mm in width by 387 mm in height. The NAC002.01 Rearframe Weldment connects to the mainframe and supports the controller cabinet. The rearframe weldment measures approximately 1188 mm in height by 1061 mm in width.

The applicable subheading for the NW100/Panel-Upper Rear Control (Part #1002115), the Panel-Lower Rear (Part #1002116), the Plate-AC Filter Mounting (Part #1002125), the Plate-Power Converter Bed (Part #1002130) and the NAC002.01 Rearframe Weldment (Part #1001113) 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 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 Ann Taub at (646) 733-3018.

Sincerely,

Thomas J. Russo
Director
National Commodity Specialist Division