CLA-2-85:OT:RR:NC:N4:120
Hope Sirekis
Marquardt Switches Inc.
2711 Route 20 East
Cazenovia, NY 13035
RE: The tariff classification of a flexible printed circuit board assembly from Thailand
Dear Ms. Sirekis:
In your letter dated January 6, 2017 you requested a tariff classification ruling.
There are four items under consideration which are all referred to as Flexible Printed Circuits (FPCs). The first three FPCs, part numbers 584097012, 584266012, and 584207012, each consist of an assembly of two light emitting diodes (LEDs) and two resistors which are mounted onto a flexible printed circuit board. The fourth FPC, part number 584095022, consists of an assembly of one LED and one resistor which are mounted onto a flexible printed circuit board. All of the FPC assemblies have the LED and resistor components mounted on one end with the other end being terminated with printed contacts for incorporation into an electrical switch assembly. The subject FPCs are said to be specifically designed for use with an electric door switch assembly for motor vehicles.
In your request, you suggest the FPCs are properly classified under 8534.00.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Printed circuits: Other: Flexible type." These printed circuits consist of circuit pathways which are printed onto an insulated base that cannot include separately produced electrical elements. As the instant FPCs include LEDs and resistors, which are separately produced and then mounted onto this flexible circuit board, the product is beyond a mere printed circuit and is now a printed circuit assembly. As such, heading 8534 is not appropriate.
The applicable subheading for the Flexible Printed Circuits, part numbers 584097012, 584266012, 584207012, and 584095022 will be 8538.90.3000, HTSUS, which provides for parts suitable for use solely or principally with the apparatus of heading 8535, 8536 or 8537: Other: Printed circuit assemblies: Other. The rate of duty will be 3.5 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 https://hts.usitc.gov/current.
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 Karl Moosbrugger at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division