CLA-2-84:S:N:N1: 105 892522
Mr. H. Rudy Ehrat
Unitrans International Corporation
700 South Hindry Ave.
Inglewood, CA 90301
RE: The tariff classification of ceramic welding nozzles from the United Kingdom
Dear Mr. Ehrat:
In your letter dated November 16, 1993 you requested a tariff classification ruling on behalf of Weldcraft Products Inc.
The ceramic nozzles are parts of torches used in gas tungsten-arc welding (often called TIG welding). TIG welding is an electric arc welding process in which the heat is produced between a nonconsumable electrode and the work metal. The electrode, the weld puddle, the arc, and adjacent heated areas of the workpiece are protected from atmospheric contamination by a gaseous shield of inert gas.
You indicate that you have previously entered these nozzles under subheading 8547.10.8000, Harmonized Tariff Schedule of the United States (HTS), which provides for other insulating fittings for electrical machines. It is clear from the explanatory notes that the items provided for in headings 8546 and 8547 are items which provide electric insulation, not the heat insulation your nozzles afford. On page 1406 of the explanatory notes for heading 8546 we read: "Insulators of this heading are used for the fixing, supporting or guiding of electric current conductors while at the same time insulating them electrically from each other, from earth, etc." The next sentence then states that insulated fittings are classifiable in heading 8547 rather than this heading. It is thus obvious that insulated fittings, like insulators, must be items that provide electrical insulation. Your nozzles do not do this.
The applicable subheading for the ceramic welding nozzles will be 8515.90.2000, HTS, which provides for parts of electric (including electrically heated gas) welding machines and apparatus. The rate of duty will be 2 percent ad valorem.
This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.
Jean F. Maguire
New York Seaport