Mr.William J. Polkinhorn
Bill Polkinhorn, Inc.
2401 Portico Blvd.
Calexico, CA 92231

RE: The tariff classification of an igniter from Mexico.

Dear Mr. Polkinhorn:

In your letter dated September 11, 2009, you requested a tariff classification ruling on behalf of Robertshaw Controls Co., Grayson Controls Division.

The item in question, a photo of which was submitted, is identified as part # 42535, “igniter with lead assembly.” It consists of an ignition electrode (stainless steel) housed in a ceramic body mounted on a bracket. An insulated electrical cable, referred to as a plastic-coated lead wire, is connected to the back end of the electrode. The device will be used to light natural or LP gas fuel in gas-fired heater systems. In such systems, the lead wire will be connected to an electrical pulse generator, which will provide the current needed to induce a spark at the tip of the electrode. The spark will in turn ignite the gas.

We note your suggestion that this product might fall in subheading 8548.90.0100, HTSUS, which provides, in pertinent part, for non-specified electrical parts of machinery or apparatus. However, we find that it is more specifically provided for elsewhere.

The applicable subheading for part # 42535, igniter with lead assembly, will be 9613.90.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for cigarette lighters and other lighters, whether or not mechanical or electrical, and parts thereof other than flints and wicks: parts: electrical. The general rate of duty will be 3.9%.

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 Nathan Rosenstein at (646) 733-3030.


Robert B. Swierupski
National Commodity Specialist Division