Mr. Lowell DeFrance
Russell A. Farrow
2264B Landmeier Road
Elk Grove Village, IL 60007

RE: The tariff classification of an electronic controller from China

Dear Mr. DeFrance:

In your letter dated March 22, 2012, you requested a tariff classification ruling, on behalf of your client, Tram Inc.

The merchandise under consideration is an electronic controller. It consists of an interlock controller assembly, which is a circuit board that is populated with resistors, diodes, transistors, a capacitor and a zener diode. An input electrical terminal and an output electrical terminal are connected to the populated circuit board, also known as a printed circuit assembly, all of which are housed in a plastic box. Your letter states that the part numbers that are used to identify the electronic controller are 626766-000 and 626767-000.

The manner in which the electronic controller works is that when one of three switches, which is not part of the electronic controller, closes a circuit current is sent to the interlock controller assembly. The interlock controller assembly routes the current to two separate solenoid apparatuses which control mechanical functions in an automobile. The solenoids are also not a part of the interlock controller assembly. The current from the separate switches are plugged into the input terminal of the electronic controller. The current from the interlock controller is sent out from its output terminals to the solenoids. The solenoids either lock or unlock parts of a car.

The input current from the separate switches to the input terminals of the electronic controller is 12 volts of direct current (DC). The electronic controller adapts the 12 volts DC for further use by the key solenoid and the shift lock solenoid. The output current from the output terminals of the electronic controller to the key solenoid is between 6 to 11 volts of DC and the output current from the output terminals of the electronic controller to the shift lock solenoid varies between +12 to –12 volts DC. The transistor’s power dissipation is between 0.5 and 2 watts. The electronic controller executes two electrical functions. Primarily, it converts direct current to a different voltage of direct current. Secondly, it regulates the voltage of the switched current.

You have suggested that the classification of the electronic controller should be Harmonized Tariff Schedule of the United States (HTSUS) subheading 8541.21.0095, which provides for “Transistors, other than photosensitive transistors: With a dissipation rate of less than 1 W: Other.” However, while the electronic controller contains transistors, it also contains resistors, diodes, a capacitor, and a zener diode mounted onto a printed circuit board, thus resulting in a printed circuit assembly. The printed circuit assembly is housed in a plastic box with an input terminal and an output terminal resulting in the subject electronic controller. The electronic controller is a device that converts direct current from one voltage to another voltage of direct current. It also regulates the voltage of the converted direct current. Explanatory Note (EN) 85.04 (II) states:

“The apparatus of this group are used to convert electrical energy in order to adapt it for further use… The fact that these apparatus often incorporate auxiliary circuits to regulate the voltage of emerging current does not affect their classification in this group.”

EN 85.04 (II) (D) further states:

“This group includes direct current converters by which direct current is converted to a different voltage.”

As the electronic controller converts direct current from one voltage to direct current of a different voltage it is a direct current converter of heading 8504. As EN 85.04 (II) so states, the fact that it can also regulate the voltage does not preclude it from classification within heading 8504. Therefore, classification of the electronic controller within subheading 8541.21.0095 as a transistor is inapplicable.

The applicable subheading for the electronic controller (part numbers 626766-000 and 626767-000) will be 8504.40.9580, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Electrical transformers, static converters (for example, rectifiers) and inductors; parts thereof: Static converters: Other: Other." The rate of duty will be 1.5 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 Hackett at (646) 733-3015.


Thomas J. Russo
National Commodity Specialist Division