Ms. Janet Westrick
Excel Global Logistics Inc.
21500 Aerospace Parkway
Brook Park, OH 44142
RE: The tariff classification of Switch Integrated Rectifier (SIR) and Remote Terminal Unit (RTU) from an unspecified country
Dear Ms. Westrick:
In your letter dated March 31, 2003, you requested a tariff classification ruling on behalf of Stock Equipment Company.
You requested the classification of a Switch Integrated Rectifier (SIR), a Remote Terminal Unit (RTU) and a Gateway II interface when imported individually as well as when imported as a complete system.
Your letter describes the Switch Integrated Rectifier (SIR) as power supply that provides electrostatic electricity for an electrostatic precipitator. Its component parts include a rectifier; static converter; transformer; copper wire coil; and electronic controls. The SIR is a power converter that converts current, frequency, and voltage. It operates 24 hours a day/7days a week and is used predominantly by coal-fired power plants. The SIR converts a low voltage alternating current (AC) into a high voltage direct current (DC) and is available in several input/output capacities. The SIR can take an AC input of 400 to 600 volts at 50 to 60 hertz and provide a DC output of 60,000 to 90,000 volts with a handling capacity of 50 to 90 kVA and an output power of 50 to 90 kW.
The Remote Terminal Unit (RTU) is described in your letter as a “hard wired remote control” that is 10in x 4in x 1.25in. It connects to the SIR like a telephone, via a cable and jack. It transfers operating instructions from a human operator to the SIR prompting the SIR, for example, to start up and run at specific capacities. Its component parts include a printed circuit board; connectors; electronic components; microprocessor; connectors; resistors; and capacitors. The RTU is not a brain. It is an alphanumeric and graphic interface, which enables a human operator to communicate instructions to the SIR.
The applicable subheading for the Switch Integrated Rectifier (SIR), when imported separately, will be 8504.40.9540, Harmonized Tariff Schedule of the United States (HTS), which provides for “Static converters: Other: Rectifiers and rectifying apparatus: Power supplies: Other.” The rate of duty will be 1.5 percent ad valorem.
The applicable subheading for the Remote Terminal Unit (RTU), when imported separately, will be 8537.20.0040, Harmonized Tariff Schedule of the United States (HTS), which provides for “Other boards, panels, …, and other bases, …, for electric control or the distribution of electricity, …: For a voltage exceeding 1,000 V.” The rate of duty will be 2.7 percent ad valorem.
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 Linda M. Hackett at 646-733-3015.
Your inquiry does not provide enough information for us to give a classification ruling on the Gateway II interface, when imported separately. Since we do not have sufficient information to determine the classification of the Gateway II interface, we cannot furnish the classification of the SIR, RTU, and Gateway II interface when imported together at this time. Once you furnish a response to items 1-4 below, we will be able to determine the classification of the Gateway II interface when imported separately as well as when the SIR, RTU, and Gateway II interface are imported as a complete system:
1 - Please provide specifications for the Gateway II.
2 - Does the Gateway II have the capability of communicating over the Wide Area Network (WAN)? If so, what component or components performs this function? Please explain fully.
3 - Please specify the type of “host computer” this device is designed to interface with. What are the requirements for such a “host computer” (e.g. what type of processors, processor specifications, operating system, etc.)? Is the “host computer” freely programmable by the user, or can it only be programmed or reprogrammed by the manufacture/seller? Is the “host computer” limited to certain programs or applications? Please explain fully.
4 - How does the Switch Integrated Rectifier (SIR), Remote Terminal Unit (RTU), and Gateway II interface interact with one another when imported together as a complete system? What is the main purpose of these three items when imported together as a complete system?
When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.
Robert B. Swierupski