CLA-2-85:OT:RR:NC:N2:220
Rachael Barnes
TE Connectivity
2801 Fulling Mill Road
Middletown, PA 17057
RE: The tariff classification of electrical terminal block modules and rail from Mexico.
Dear Ms. Barnes:
In your letter dated August 25, 2022, you requested a tariff classification ruling.
The first item under consideration is identified as the CTD Terminal Junction Bussing Module (Bussing Module), PN CTD160E01F, which is described as a rectangular electrical terminal block made up of a molded plastic body, an internal bus bar, gaskets/seals, and 8 electrical socket contacts. Internally, the Bussing Module incorporates pin-buss bars to make and share electrical connections across multiple terminals. In use, individual wires/contact pins are inserted into the module, which is fastened into a rail or panel mounting system to provide electrical connections. The Bussing Module is said to be rated at 600 VAC.
The second item under consideration is identified as the CTJ Feedback Module (Feedback Module), PN CTJ116E01D-513, which is described as a rectangular electrical terminal block made up of a molded plastic body, an internal bus bar, gaskets/seals, and 6 electrical socket contacts. Internally, the Feedback Module incorporates a pin-buss bar to make and share electrical connections across multiple terminals. In use, individual wires/contact pins are inserted into the module, which is fastened into a rail or panel mounting system to provide electrical connections. The Feedback Module is said to be rated at 600 VAC.
The third item under consideration is identified as the CTJ In-line Receptacle Connector Assembly (Receptacle Module), PN CTJ920R06N-513, which is described as a rectangle electrical connector made up of a molded plastic body with an internal bus bar, gaskets/seals, and 6 electrical contacts. Internally, the Receptacle Module incorporates a pin-buss bar to make and share electrical connections across multiple terminals. In use, individual wires/contact pins are inserted into the Receptacle Module to establish electrical connections. The Receptacle Module is said to be rated at 600 VAC.
The fourth item under consideration is identified as the CTJ4 Series Electronic Component Module (Component Module), PN CTJ420E005-513, which is described as a rectangle electrical terminal block made up of a molded plastic body with an internal bus bar, gaskets/seals, and 10 electrical contacts. In addition, the Component Module is equipped with an internal printed circuit board assembly having multiple discrete electronic components, such as diodes, resistors, capacitors, and fuses. In use, individual wires/contact pins are inserted into the Component Module to establish electrically filtered and protected connections. The Component Module is said to be rated at 600 VAC.
The fifth item under consideration is identified as the Terminal Junction Rail Assembly (Rail Assembly), PN 591642-2, which is described as an aluminum mounting rail that is populated with nine Feedback Module Assemblies.
In your request, you suggest the Receptacle Module is properly classified under subheading 8536.69.8000, Harmonized Tariff Schedule of the United States (HTSUS). We disagree.
The General Rules of Interpretation (GRIs) to the HTSUS govern the classification of goods in the tariff schedule. GRI-1 states, in pertinent part, "For legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes . . . ." In addition, although not dispositive, the Explanatory Notes (ENs) to the Harmonized Commodity Description and Coding System represent the official interpretation of the tariff at the international level and facilitate classification under the HTSUS by offering guidance in understanding the scope of the headings and the GRIs.
The ENs to heading 8536, HTSUS, part (III), provides for apparatus for making connections to or in electrical circuits. Specifically, EN 85.36 (III)(B) describes terminals and terminal strips as follows:
These include small squares of insulating material fitted with electrical connectors (dominoes), terminals which are metal parts intended for the reception of conductors, and small metal parts designed to be fitted on the end of electrical wiring to facilitate electrical connection (spade terminals, crocodile clips, etc.).
Terminal strips consist of strips of insulating material fitted with a number of metal terminals or connectors to which electrical wiring can be fixed. The heading also covers tag strips or panels; these consist of a number of metal tags set in insulating material so that electrical wires can be soldered to them. Tag strips are used in radio or other electrical apparatus.
It is the opinion of this office that the subject Bussing, Feedback, and Receptacle modules are accurately described as terminal strips (blocks). As such, the applicable subheading for the CTD Terminal Junction Bussing Module, PN CTD160E01F, the CTJ Feedback Module, PN CTJ116E01D-513, and the CTJ In-line Receptacle Connector Assembly, PN CTJ920R06N-513, will be 8536.90.4000, HTSUS, which provides for “Electric apparatus for switching or protecting electric circuits, or for making connections to or in electrical circuits…: Other apparatus: Terminals, electrical splices and electrical couplings; wafer probers.” The general rate of duty will be Free.
However, we would note that the Component Module incorporates one or more fuses in addition to the terminal strip. Likewise, the Rail Assembly consists of multiple Feedback Modules mounted on aluminum frame. Consequently, the heading description for 8537 is met directly as both the Component Module and the Rail Assembly incorporate two or more apparatus of heading 8536, while both function to electrically connect and/or protect electrical circuits. Thus, the applicable subheading for the CTJ4 Series Electronic Component Module, PN CTJ420E005-513, and the Terminal Junction Rail Assembly, PN 591642-2, will be 8537.10.9170, HTSUS, which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Other”. The general rate of duty will be 2.7 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 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