N120 W19129 Freistadt Rd
Germantown, WI 53022
RE: The tariff classification of end plates from Germany
Dear Mr. Kenworthy:
In your letter dated May 15, 2019 you requested a tariff classification ruling.
The merchandise under consideration is referred to as a terminal block end plate and is described as a molded plastic end cap for a DIN rail mountable terminal block assembly. The subject end plate is specifically molded to fit onto the side of the last terminal block in an assembly and completes the outermost housing to form an enclosure. While the end plate does supply electrical separation from exposed contacts, in our view its principal function is to provide the side enclosure to the terminal block assembly
In your request, you suggest these goods be classified under 8546.90.0000 which provides for "Electrical insulators of any material: Other". We disagree. The subject end plates are not specifically designed for the insulation of electrical current in that they do not reduce or prevent the transmission of electricity as their primary function. Goods classified in this subheading are defined as those used to support, guide, or fix the electrical current conductors while at the same time insulating them from one another. As this is not the primary function of these goods, they are precluded from classification under heading 8546.
The applicable subheading for the terminal block end plate will be 8538.90.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for molded parts suitable for use solely or principally with the apparatus of heading 8535, 8536, or 8537. The general 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 the World Wide Web at https://hts.usitc.gov/current.
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 Karl Moosbrugger at firstname.lastname@example.org.
Steven A. Mack
National Commodity Specialist Division