Mr. James Shaw
Panasonic Logistics Company
2 Panasonic Way
Secaucus, NJ 07094
RE: The tariff classification of Aluminized PET Sheeting, Cover Film, Capacitor Element, and Capacitor Case from Japan
Dear Mr. Shaw:
In your letter dated October 24, 2000, you requested a tariff classification.
The Aluminized PET Sheeting is used in the production of aluminum capacitors. The sheeting consists of .5 microns of aluminum particles spattered onto 4-5 microns of polyethylene terephthalate (PET) film. The Aluminized Sheeting is imported on rolls from Japan. The Aluminized Sheeting will be used to produce aluminum electrolytic capacitors in the United States.
The Cover Film is made of paper coated with polyethylene terephthalate (PET) plastics. The thickness of the PET exceeds the thickness of the paper; the thickness of the PET portion of the film is 200 microns and the thickness of the paper is 100 microns. The Cover Film is imported on rolls from Japan. After importation, the Cover Film is placed on a machine that unwinds and then re-rolls it with the Aluminized Sheeting described above. Afterwards, the combined Cover Film and Aluminized Sheeting are utilized to produce Capacitor Elements in the United States.
The Capacitor Element contains the sealed internal components of an aluminized film capacitor. You state that those components are aluminized film, cover paper and zinc powder. After importation, a Capacitor Case will be attached to the Capacitor Element. In its imported condition, the Capacitor Element contains the components of a fixed aluminum electrolytic capacitor. This item will be imported in varying voltages ranging between 100 to 250 volts, depending on the specifications. The origin of the Capacitor Element is Japan.
The Capacitor Case is made of a hard plastic, which has been molded to shape to accept a Capacitor Element. The Capacitor Case is joined and sealed to the Capacitor Element during an assembly process after importation. Each Capacitor Case is solely used with and designed to the specifications of each individual Capacitor Element. The origin of the Capacitor Case is Japan.
The applicable subheading for the Aluminized PET Sheeting will be 3920.62.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Other plates, sheets, film, foil and strip, of plastics… Of polycarbonates, alkyd resins, polyallyl esters or other polyesters: Of polyethylene terephthalate.” The rate of duty will be 4.2 percent ad valorem.
The applicable subheading for the Cover Film will be 3921.90.4010, Harmonized Tariff Schedule of the United States (HTS), which provides for “Other plates, sheets, film, foil and strip, of plastics… Other: Other: Flexible: Reinforced with paper.” The rate of duty will be 4.2 percent ad valorem.
The applicable subheading for the Capacitor Element will be 8532.22.00, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electrical capacitors: Other fixed capacitors: Aluminum electrolytic.” The rate of duty will be free.
The applicable subheading for the Capacitor Case will be 8532.90.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electrical capacitors; parts thereof: Parts.” 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 Linda M. Hackett at 212-637-7048.
Robert B. Swierupski