CLA-2-85:OT:RR:NC:N1:112
Darlene Enlow
GE Optimization Control
7 Independence Pointe
Suite 300
Greenville, SC 29615
RE: The tariff classification of a Transducer System
Dear Ms. Enlow:
In your letter dated May 22, 2012, you requested a tariff classification ruling.
The item concerned is referred to as the 3300 5mm Proximity Transducer System. You state that this system allows direct observation of shaft or target displacement for a variety of vibration, position, speed and timing measurements. The system is made up of a 3300 5mm probe, 3300 XL extension cable and the 3300 XL Proximitor Sensor.
This system uses Eddy Current technology to sense vibration within various industrial applications. The “Probe” portion of the system is a type of transducer. It is made from molded resin that incorporates an inductor. The “Probe” transforms the physical movement/vibrations from the rotating shafts into an electrical current/signal. The extension cable is used to direct that energy to the Proximitor Sensor. The Proximitor Sensor receives the electrical current/signal and converts it for use by another component (the 3300 Rack, not included).
Regarding your proposed classification in HTSUS 9031.80.8085, the description you attached states that its “primary use is in vibration and position measurement applications on fluid-film bearing machines as well as Keyphaser measurement and speed measurement applications.” This Proximity Transducer does not measure vibration. Rather, by the information that it provides about the object becoming closer or farther away from its probe, other equipment can determine, especially by measuring the time intervals between those events, the frequency of the
vibration, etc. Similarly, in speed measurement applications, the output of the proximity sensor near the location where gear teeth pass by enables other equipment to determine the number of teeth that have passed and, by knowing the number of teeth per revolution and dividing by the time it has measured, that equipment can calculate the revolutions per minute, etc. This is similar to the use of the rotary encoder in Headquarters Ruling Letter 964599, December 22, 2000, which was not classified in HTSUS Chapter 90.
The applicable subheading for the 3300 5mm Proximity Transducer System will be 8543.70.9650, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Other machines and apparatus: Other: Other: Other: Other.”
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 Steven Pollichino at (646) 733-3008.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division