Ms. Rachelle M. Smith
Nissin Customs Service, Inc.
609 W. Dempster St.
Mount Prospect, IL 60056
RE: The tariff classification of electric heating elements/resistors from China.
Dear Ms. Smith:
In your letter dated July 17, 2007 you requested a tariff classification ruling on behalf of your client SJH Inc. Descriptive literature and illustrations were submitted.
The items in question are two heating elements/resistors to be used in a wide range of products such as electric stoves, electric ovens, electric water steamers, water heaters, etc. An illustration of the first product depicts a stove-top heating element designed for use with domestic electric ranges. It is a concentric insulated coil that has two male electrical connectors to permit the element to be snap fitted into corresponding female fittings on the range top.
A special fitting is crimped to the ends of the male connectors to ensure their uniform spacing when inserted into the range. A three prong, Y-shaped support or brace is welded to the underside of the heating element to keep it squarely above a metallic dish which catches droppings from the stove. Finally, a metallic top cap is crimped in the middle of the heating element to provide a more even surface height to the element and to add decoration.
The second product appears to be an elongated, U-shaped heating element which incorporates wire connections.
In your request you suggest the heating elements are classified under subheading 8516.80.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other electric heating resistors. However, based on the information submitted we find the electric heating elements are classified under subheading 8516.90 because they are advanced beyond the scope of the subheading you suggest.
The applicable subheading for the stove-top heating element will be 8516.90.8000, HTSUS, which provides for other parts for the cooking stoves, ranges and ovens of subheading 8516.60.40. The duty rate is 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 World Wide Web at http://www.usitc.gov/tata/hts/.
Your inquiry does not provide enough information for us to give a classification ruling on the elongated, U-shaped heating element. Please provide a detailed description of the heating element. Indicate what the element is made of; explain how it generates heat and how and where it is used. When this information is available, you may wish to consider resubmission of your request. If you decide to resubmit your request, please include all of the material that we have returned to you.
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 Kenneth T. Brock at 646-733-3009.
Robert B. Swierupski