CLA-2-85:OT:RR:NC:N2:209
Mr. Edgar Prado
Carbontec Worldwide, LLC
1920 East Hallandale Beach Boulevard, Suite 900A
Hallandale Beach, FL 33009
RE: The tariff classification of an electrical heating film from Germany
Dear Mr. Prado:
In your letter dated November 7, 2018, you requested a tariff classification ruling.
The item concerned is referred to as Carbontec® Heating Film (part #’s 251-L and 251-S). This film is made from a high-tech carbon fiber polymer. Embedded in the carbon film are copper strips running along the sides. It is flocked with NapTouch® and perforated. It is imported in rolls and can be cut by installers perpendicular to the copper strips.
Carbontec® Heating Film is a critical element of a coil-less radiant heating system. The film (heating element) is intended to be installed behind ceilings and under floors. When attached to a transformer, the film generates and distributes radiant heat.
The applicable subheading for the Carbontec® Heating Film (part #’s 251-L and 251-S) will be 8545.90.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Carbon electrodes, carbon brushes, lamp carbons, battery carbons and other articles of graphite or other carbon, with or without metal, of a kind used for electrical purposes: Other: Other.” 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 the 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 Steven Pollichino at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division