CLA-2-85RR:NC:MM:109 F80316

Mr.James Shaw
Panasonic Logistics Co.
2 Panasonic Way
Secaucus, NJ 07094

RE: The tariff classification of Mounted Piezoelectric Elements from Japan

Dear Mr. Shaw:

In your letter dated December 1, 1999, you requested a tariff classification ruling.

The merchandise is described in your letter as Mounted Piezoelectric Element Models FEEL, EFER and EFET. These Elements are used in alarm mechanisms in clocks and watches. The units are assembled into a resonance housing (enclosure) to produce a sound and are quartz discs. The discs are coated with silver with a thickness of 3 to 5 micrometers. The silver is painted on both sides of the disc and acts as an electrode. The electrode works as an electrical terminal to contact the piezoelectric crystal with the terminal of the alarm clock circuits in the clock case. These elements are designed to operate at 70 kHz to 200 kHz. A sample of the Piezoelectric Element and watch and a diagram showing the component construction of the product was submitted to this office.

Explanatory Note 85.41(D) reads as follows: “They are classified here only if mounted. They are generally in the form of plates, bars, discs, rings, etc. and must, at least, be equipped with electrodes or electric connections.”

The applicable subheading for the Mounted Piezoelectric Elements will be 8541.60.0020, Harmonized Tariff Schedule of the United States (HTS), which provides for “Mounted piezoelectric crystals: Quartz designed for operating frequencies of: Not exceeding 1 MHz, except 32.768 kHz.” The rate of duty will be free.

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 Eileen S. Kaplan at 212-637-7048.


Robert B. Swierupski
National Commodity
Specialist Division