Ms. Marilee Rice
Woodward Governor Company
P.O. Box 1519
Fort Collins, CO 80522-1519
RE: The tariff classification of Electrically Powered Governor Systems
Dear Ms. Rice:
In your letter dated August 9, 2004, you requested a tariff classification ruling. No samples were submitted.
The information you supplied states:
“In operation, the control compares the speed of the engine with the desired speed or desired load and sets the actuator position to correct discrepancies.
The EPG is designed for precise speed control of diesel, gas, gasoline engines, and gas turbines.
Each Woodward Electrically Powered Governor (EPG) system includes three basic parts:
A magnetic pickup (MPU) which senses engine speed from an engine-driven gear.
A speed control which receives the speed signal from the MPU, compares it to a reference signal, and generates a control signal which the control sends to the actuator.
An actuator which receives the signal from the control and positions its output shaft according to this signal. This output shaft is linked to the fuel control.”
Per NIS J. Sheridan’s telephone conversation on October 7, 2004 with N. Neumon of your firm:
The load is never measured by the device. Rather, the purchaser would know for their particular large motor what percent of load would be equivalent to a given rpm.
The controller is analog, not digital, and thus has no software.
The actuator physically moves a lever, etc on the throttle of the large motor to assure that the desired rpm is maintained, much like the way that an automobile cruise control moves the gas pedal to achieve and maintain the desired speed.
The MPU is like a rotary encorder in that it only sends pulses of electricity when the shaft of the large motor reaches certain points in its revolution.
The Options listed are not integral to the EPGS and are not included in your ruling request.
The applicable subheading for the MPU, imported separately, will be 8543.89.4000 Harmonized Tariff Schedule of the United States (HTS), which provides for, inter alia, Electric Synchros and Transducers.
The applicable subheading for the 60 watt actuator will be 8501.31.2000 and for the 95 watt actuator will be 8501.31.4000, Harmonized Tariff Schedule of the United States (HTS), which provide for “other” DC motors.
The applicable subheading for both the controller imported separately and the EPGS imported together as a unit will be 9032.89.6085, Harmonized Tariff Schedule of the United States (HTS), which provides for “Other” Automatic Regulating or Controlling Instruments and Apparatus which only perform the function described in Note 7 to HTS Chapter 90.
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 J. Sheridan at 646-733-3012.
Robert B. Swierupski