CLA-2-85:OT:RR:NC:1:110
Ms. Stephanie Ms. Sippel
International Customs Services, Inc.
N64 W24801, Main St., Suite 121
Sussex, WI 53089
RE: The tariff classifications of a pressure switch conversion kit.
Dear Ms. Sippel:
In your letter dated July 25, 2011, you requested a tariff classification ruling on behalf of your client, York International Corp.
The item under consideration is a Natural Gas to Liquid Propane Conversion Kit (1NP0347). A sample of the kit was submitted with your ruling request and will be returned to you. The kit consists of a number of components from multiple countries and is designed to convert a furnace from natural gas to liquid propane (LP). The submitted sample kit includes a pressure switch (P/N 17471), a tapped gas pipe nipple (P/N 18095), several propane gas orifices (P/N 18081), wire harness (P/N 20461), valve conversion kit (P/N 7614), installation instructions and caution/warning labels.
From the information that you have provided, the pressure switch is an electrical switch that is actuated by a change in gas pressure. When a predetermined value is achieved the pressure switch will open or close an electrical circuit to cause the furnace to lock out if the gas supply pressure drops below 6” w.c. and the ignition control on the furnace will display a fault and reset after one hour. This is to prevent a build up of soot in the furnace due to low gas pressure or low gas in the propane tank. The pressure switch consists of an electrical micro switch with normally open (NO) and normally closed (NC) contacts housed within a plastic enclosure with an actuating mechanism that is threaded into the tapped gas pipe nipple, which will be installed into the gas supply pipe. The orifices are required to replace the original natural gas orifices for proper combustion of the different gases. The wiring harness is used to connect the pressure switch to the flame sensor on the furnace. The valve conversion kit (P/N 7614) consists of springs for replacing the original regulator springs on the gas valve, which is necessary due to the difference in gas pressure. The Natural Gas to Liquid Propane Conversion Kit provides a safety switch to disconnect power to the furnace due to low gas pressure or no gas in the propane tank, which is necessary in a gas conversion for the furnace to function safely. The Natural Gas to Liquid Propane Conversion Kit meets the definition of “goods put up in sets for retail sale.” As per GRI 3(b), classification is determined by the component, or components taken together, which confer on the set as a whole its essential character. The pressure switch clearly provides the essential character of this kit.
The applicable subheading for the Natural Gas to Liquid Propane Conversion Kit (1NP0347) will be 8536.50.9065, HTSUS, which provides for “Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits…Other switches: Other: Other: Other.” The general rate of duty will be 2.7 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