Mr. Sydney H. Mintzer
Mayer Brown LLP
1909 K Street, NW
Washington, DC 20006
RE: The tariff classification of parts of wind turbine generators of unspecified origin
Dear Mr. Mintzner:
In your letter dated December 14, 2007 you requested a tariff classification ruling on behalf of Suzlon Wind Energy Corporation.
The articles you plan to import are described as parts of a wind turbine generator: the nacelle assembly, the hub, the blade and the nose cone; and the tower upon which the wind generator set is mounted. Each item will be imported separately.
The nacelle assembly is a structure that houses a generator, gearbox, rotor shaft, main frame and bed plate among other components. It is primarily responsible for converting wind energy into electrical energy.
The hub is the component that fits onto the end of the nacelle assembly. It is made of cast iron and shaped into spheres. The primary function of the hub is to hold the blades in place.
The nose cone is installed to the hub and provides access to the hub. It protects the hub from the elements and improves aerodynamics by speeding up air flow as it approaches the blades.
The blades are made of a fiberglass epoxy and measure 43.35 meters in length. They fit into the hub and move in response to wind energy.
The wind turbine generator is mounted to a tower. A completed tower stands 77.5 meters in height. A tower is composed of flat-rolled steel pieces welded together to form sections of a long, tubular structure. The sections are bolted together and a wind turbine generator is secured to the top.
The applicable subheading for the nacelle assembly will be 8502.31.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other electric generating sets, wind-powered. The rate of duty will be 2.5 percent ad valorem.
The applicable subheading for the hub, the nose cone and the blades will be 8412.90.9080, HTSUS, which provides for parts of other engines and motors. The rate of duty is free.
The applicable subheading for the tower will be 7308.20.0000, HTSUS, which provides for towers and lattice masts. The rate of duty 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/.
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