CLA-2-85:OT:RR:NC:N2:220
James Pai
BDO USA LLP
600 Anton Boulevard, Suite 500
Costa Mesa, CA 92867
RE: The tariff classification of electrical tabs from Japan
Dear Mr. Pai:
In your letter dated May 13, 2022, you requested a tariff classification ruling on behalf of your client, LG Energy Solution Michigan, Inc.
The merchandise under consideration is identified as the Plus-side Lead and the Minus-side Lead, which are described as electrical contacts that are incorporated into a lithium-ion battery cell. The Leads are rectangular in shape and are equipped with an adhesive/insulative strip where they exit the battery. The Plus-side Lead is comprised of aluminum while the Minus-side Lead is made from nickel-plated copper. In use, the Leads form the positive and negative poles to electrically connect the battery to an electrical load.
In your letter, you suggest that the subject electric tabs are classifiable under subheading 8536.90.4000, Harmonized Tariff Schedule of the United States (HTSUS). As the subject electrical tabs are not terminals, splices, or couplings, we disagree with the suggested classification.
The applicable subheading for the Plus-side Lead and the Minus-side Lead will be 8536.90.8585, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Electrical apparatus…for making connections to or in electrical circuits…for a voltage not exceeding 1,000 V: Other apparatus: Other: Other." The general 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 Karl Moosbrugger at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division