CLA-2-85:OT:RR:NC:N1:109

Paula M. Connelly Law Offices of Paula M. Connelly 67 South Bedford Street, Suite 400 West Burlington, MA 01803

RE:  The tariff classification of Resistance Temperature Detectors from Costa Rica Dear Ms. Connelly: In your letter dated May 5, 2015, you requested a tariff classification ruling on behalf of your client, RdF Corporation. This ruling covers five types of passive temperature sensors (resistors), two of which are described as wire-wound resistors and three as metal film resistors. All of these resistors are known in the industry as a “thermistor” whose resistance changes based upon temperature. However, these resistors do not measure temperature the way a thermometer or thermostat does. They are designed to provide an input to instruments that measure either temperature or energy relative to some reference. Typical applications for these resistors include jet aircraft windscreens and control systems, high speed locomotive windscreens, hybrid electronic automobile transmissions, and medical diagnostic research, to name a few. The submitted samples identified as RdF part numbers 22810 and 24984, are wire-wound resistors comprised of two conductor lead wires (26awg stranded nickel plated copper and 28awg solid tinned copper, respectively) attached to a sensing element, the latter of which is firmly embedded into a plastic insulated film. The operating temperature range for these resistors is measured in degrees and their resistance is measured in ohms. The submitted samples identified as RdF part numbers 29227, 29231, and 29662, are metal film resistors, each of which are comprised of two conductor lead wires and platinum sensing elements sealed in cylindrical housings. Part number 29227 provides up to 10,000 ohms of resistance, while part numbers 29231 and 29662 each provide up to 1,000 ohms of resistance. The applicable subheading for the wire-wound resistors, RdF part numbers 22810 and 24984 will be 8533.21.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical resistors (including rheostats and potentiometers), other than heating resistors; parts thereof: Other fixed resistors: For a power handling capacity not exceeding 20 W: Other: Wirewound.” The rate of duty will be Free. The applicable subheading for the metal film resistors, RdF part numbers 29227, 29231, and 29662 will be 8533.21.0090, (HTSUS), which provides for “Electrical resistors (including rheostats and potentiometers), other than heating resistors; parts thereof: Other fixed resistors: For a power handling capacity not exceeding 20 W: Other: Other.” The rate of duty will be Free.

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: [email protected]. Sincerely,

Gwenn Klein Kirschner Director National Commodity Specialist Division