Danivia Vasconcelos, C.C.S Certified
Customs & Traffic Manager
RCP Inc.
2891 Langstaff Road
Concord, Ontario, Canada L4K 4Z2

RE: The tariff classification of an insulating washer from China

Dear Ms. Vasconcelos:

In your letter dated June 25, 2008, you requested a tariff classification ruling.

The item concerned is an insulating washer (Part # 23235). This circular shaped insulator has an inner diameter of 0.400 inches and an outer diameter of 0.880 inches. It is yellow in color and comprised of glass laminate and epoxy resin.

The insulator will be used in starter motor assemblies. The item is used to insulate an electrical post from a steel tube housing.

You proposed classification under subheading 8546.10.00.00, Harmonized Tariff Schedule of the United States (HTSUS) which provides for “Electrical insulators of any material: Of glass.” However, it is the opinion of this office that the insulator (Part # 23235) is more specifically provided for in subheading 8547, which provides for “Insulating fittings for electrical machines…:”

The applicable subheading for the insulating washer (Part # 23235) will be 8547.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Insulating fittings for electrical machines, appliances or equipment, being fittings wholly of insulating material…: Insulating fittings of plastics. The rate of duty will be 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

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 Steve Pollichino at 646-733-3008.


Robert B. Swierupski
National Commodity
Specialist Division