Jon R. Weiner
Customs Compliance Specialist
Rolls-Royce North America
2001 S. Tibbs Avenue
Indianapolis, IN 46241

RE: The tariff classification of a feedback transmitter assembly from Sweden, Finland or Norway.

Dear Mr. Weiner:

In your letter dated October 1, 2010, you requested a tariff classification ruling.

The item concerned is referred to as a feedback transmitter assembly. It consists of a potentiometer and a circuit board within a common housing. The potentiometer incorporates a rotating axis that extends beyond the housing. The external portion of the axis allows the assembly to be mechanically connected to a ship’s propulsion system. The assembly is connected to the propulsion system via cables or steel levers and rods.

In use, the feedback transmitter assembly is mechanically connected to a ship’s propulsion system. When the propulsion system moves, the axis of the potentiometer rotates. The rotation of the potentiometer’s axis generates an electrical signal that corresponds to the degree of movement and the direction of the ship’s propulsion system. The electrical signal travels from the potentiometer to the printed circuit board. From the printed circuit board a digital signal goes out, via wires, to a bridge control panel. A signal converter in the panel unit converts the digital signal to an analogue signal. That analogue signal is transmitted to an analogue indicator with a mechanical pointer. The indicator displays the degree of rotation and direction of the propulsion system. The types of potentiometers used in the feedback transmitter assembly are either wire-wound or carbon-type, both with a power handling capacity of less than 20 watts.

You propose classification of the feedback transmitter assembly under subheadings 8533.31.0000 or 8533.40.8070. It is Customs opinion that the subheadings within heading 8533 that provide for potentiometers, provide solely for the potentiometer. The feedback transmitter assembly consists of additional components as opposed to only a potentiometer. Based on the construction and function of this device it appears to be beyond the scope of a potentiometer of heading 8533.

The applicable subheading for the feedback transmitter assembly will be 8543.70.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Other machines and apparatus: Electric synchros and transducers;…”. The general rate of duty will be 2.6%.

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 Steven Pollichino at (646) 733-3008.


Robert B. Swierupski
National Commodity Specialist Division