CLA-2-85:OT:RR:NC:1:110
Mr. Damon V. Pike
The Pike Law Firm, P.C.
127 Peachtree Street, N.E.
Suite 923
Atlanta, GA 30303
RE: The tariff classification of control modules and a sensor from an unspecified country.
Dear Mr. Pike:
In your letter dated July 28, 2009 you requested a tariff classification ruling on behalf of your client, Weber, Inc.
The merchandise under consideration are the Elau PacDrive Motor Controller, Model C400 (Weber part number 101045); the Lenze 8200 Vector Frequency Inverter, Model E82EV552K4C (Weber part number 100809); the Berger Lahr (SIG Positec) Power Drive for Three-Phase Stepping Motors, Model WD3-008.1801 (Weber part number 100902); and the Baumer Ultrasonic Proximity Sensor with Analog Output, Model UNDK 30U61/405468 (Weber part number 132431). From the information you provided, all four articles are designed for controlling modern packaging machines and a meat and cheese slicing machine.
The Elau PacDrive Motor Controller, Model C400 is a motion logic control for customized automation systems. These systems are universally applicable for production machinery, primary and secondary packaging, end-of-line packaging and robotics. The C400 is a microprocessor based controller that can synchronize the control of up to 16 servo axes. It is encased in a metal housing measuring approximately 4 inches wide by 10¾ inches high by 9? inches deep. From the information provided the C400 controller contains programmable memory for the storage of instructions, up to 32 megabytes (MB) of Compact Flash, 256 MB of SD/DDR RAM, and up to 256 kilobytes (KB) of NV RAM. The front of the housing features 10 terminal strips, an RJ-series socket, push-button switches, “D” type data connectors, and a display. The C400 is a low voltage Programmable Logic Controller (PLC) with field-bus connectivity for I/O modules, Ethernet interface and other field-bus interface.
The Lenze 8200 Vector Frequency Inverter is a universal plug-in module used to control electric motors. It implements electronic variable speed drives for a multiplicity of applications. The Lenze 8200 is encased in a metal and plastic housing and measures approximately 9? inches high by 4 inches high by 5½ inches deep, and is rated for up to 500 Volts (V) AC and 16.8 Amps (A). It has an overload capacity of 180% rated torque for 60 seconds from 15 kilowatts (kW) upwards, and an additional 210% rated torque for 3 seconds on motor startup. From the information provided, the Vector Frequency Inverter incorporates electrical connectors and relays, and provides over-voltage and under-voltage protection, adjustable current limitation, as well as over-current warnings and fault indications. This device is operated by a separately imported eight-key keypad with text display, allowing the operator to quickly access a menu of the inverter’s parameters.
The Berger Lahr (SIG Positec) Power Drive for Three-Phase Stepping Motors consists of a power control card and a power supply encased in a metal housing, and measures approximately 2 inches wide by 9? inches high by 9? inches deep. The Power Drive controls the amount of current to and rotation of a 3-phase stepping motor. From the information provided, this device incorporates a transformer which receives 115 V AC power input and delivers 230 V DC power to the motor. It features terminal strips, LED (light emitting diode) status indicator lights, one “D” type data connector, one DIP (dual in-line) switch used to adjust the number of steps per revolution as well as the current reduction and gate/enable, and a rotary selector switch used to set the motor phase current (up to 6.8 A). It is rated for up to 240 V, and is compatible with 110 V and 325 V motors.
The Baumer Ultrasonic Proximity Sensor with Analog Output is a DC-powered ultrasonic proximity sensor that uses reflected or transmitted ultrasonic waves to detect the presence or absence of a target object within a range of 100-450 millimeters (mm). From the information provided, it is encased in a polyester/die-cast zinc housing measuring approximately 1 1/5 inches wide by 2 3/5 inches high by 1 1/5 inches deep, and is rated at 30 V DC.
The applicable subheading for the Elau PacDrive Motor Controller, Model C400 (Weber part number 101045) will be 8537.10.9060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Programmable controllers.” The general rate of duty will be 2.7 percent ad valorem.
The applicable subheading for the Lenze 8200 Vector Frequency Inverter, Model E82EV552K4C (Weber part number 100809) and the Berger Lahr (SIG Positec) Power Drive for Three-Phase Stepping Motors, Model WD3-008.1801 (Weber part number 100902) will be 8537.10.9070, HTSUS, which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Other.” The general rate of duty will be 2.7 percent ad valorem.
The applicable subheading for the Baumer Ultrasonic Proximity Sensor with Analog Output, Model UNDK 30U61/405468 (Weber part number 132431) will be 8543.70.4000, HTSUS, which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in the chapter…: Other machines and apparatus: Electric synchros and transducers…” The general rate of duty will be 2.6 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 http://www.usitc.gov/tata/hts/.
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 Thomas Campanelli at (646) 733-3016.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division