Mr. Sean Cole
Solutions from Science
815 West Main Street
P.O. Box 518
Thomson, IL 61285

RE: The tariff classification of Solar Generator Model PH Plus 1800

Dear Mr. Cole:

In your letter dated August 15, 2011, you requested a tariff classification ruling.

The merchandise subject to this ruling is a Solar Generator Model PH Plus 1800. It consists of two solar charging modules, four solar panels, and four 100 amp/hour, lead acid, AGM deep cycle rechargeable batteries. Attached at the back of each solar panel is a junction box with a terminal block within it. The terminal block has a power cord connected to it. The lead acid, AGM deep cycle rechargeable batteries are sealed within the battery casing of the PH Plus 1800. The PH Plus 1800 also contains an inverter. The PH Plus 1800 is fully wired and ready to use as a plug and play power generating system. It is prewired for up to 400 watts of wind turbine power enabling the user to charge the system’s batteries with the solar panels, household alternating current (AC), as well as from the ready-to-use wind turbine hook-up. As such, the user can plug the solar panel cable into a power socket on the main unit to obtain power. The PH Plus 1800 system can easily be moved from place to place for a variety of uses in and away from home, such as while camping, boating, and for remote power for construction sites.

The two solar charging modules permit the solar panels to charge/recharge the lead acid rechargeable batteries. The rechargeable batteries are used to draw up to the 1800 watts available to power for many 110 voltage household appliances, such as, televisions, radios, refrigerators, freezers and lights. The rechargeable batteries for the PH Plus 1800 can be recharged in one of two manners, i.e. by the solar panel or by a built-in alternating current (AC) charger. The four 150 watt solar panels are used to recharge the batteries within the PH Plus 1800 casing. The silicon cells that comprise the solar panels absorb photons from sunlight and convert them to direct current (DC) electricity. The DC flow is carried on aluminum ribbons that come together within the terminal block enclosed within the junction box on the back of each solar panel. The terminal block is connected to a 100 foot 12-3 cord that has a 5L-20P power connector attached to the end of the cord.

You explained within your submission that the solar panels would absorb photons from sunlight and convert them into DC electricity. The DC electricity would be transmitted along a wire to the solar charging modules which would charge the lead acid deep cycle batteries. At that point, a load would be drawn and the energy would be inverted to a modified AC wave of up to 1800 watts. The unit would then be able to provide power to various 110 VAC household appliances. Your submission also stated that the unit can function as an uninterruptable power supply (UPS) when the unit is plugged into a 120 VAC receptacle utility grid.

A photograph of the Solar Generator Model PH Plus 1800 identifies the system as four stand-along solar panels, which appear to incorporate the two solar charging modules, and the casing for the PH Plus 1800, which you stated contains the four lead acid rechargeable batteries. The solar panels/solar charging modules and the PH Plus 1800 casing containing the lead acid rechargeable batteries constitute a retail set because they are classified in separate headings, work together to charge electrical devices, and the articles are packaged together for retail sale. The solar panels/solar charging modules generate electricity and charge electrical devices, as an electric generator of heading 8501. The lead acid rechargeable batteries, within the PH Plus 1800 casing, store electricity and charge electrical devices, as rechargeable batteries of heading 8507. As was determined within headquarters’ Ruling H136116, which ruled upon similar merchandise, specifically a Sherpa Power Pack and a Nomad Solar Panel, since both functions are equally important, we cannot determine which article provides the essential character. Therefore, in accordance with General Rule of Interpretation (GRI) 3(c), the entire Solar Generator Model PH Plus 1800 system will be classified as a rechargeable battery under heading 8507, the heading that occurs last in numerical order among those which equally merit consideration.

The applicable subheading for the Solar Generator Model PH Plus 1800 will be 8507.20.80, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric storage batteries, including separators therefor, whether or not rectangular (including square): parts thereof: Other lead-acid storage batteries: Other.” The rate of duty will be 3.5 percent ad valorem.

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 Linda M. Hackett at (646) 733-3015.


Robert B. Swierupski
National Commodity Specialist Division