CLA-2-40:OT:RR:NC:N4:421
Mr. John M. Peterson
Neville Peterson LLP
17 State Street, 19th Floor
New York, NY 10004
RE: The tariff classification of rubber grommets
Dear Mr. Peterson:
In your letter dated June 14, 2012, on behalf of Amphenol Optimize Manufacturing Co. Inc., you requested a tariff classification ruling.
Representative samples were provided for examination. The products are identified as grommets made of polychloroprene synthetic rubber designed for use in a wide variety of connectors for industrial applications. The grommets are in the form of cylindrical plug-like devices of various diameters and lengths. Each contains between four and ten channels extending throughout the length for placing wires or contacts. The channels keep those wires from contact with each other or from metallic components of the cylindrical connector.
Amphenol Industrial Part Number C-10-060718-012 measures approximately 3/4 inch in diameter and 1/2 inch in length and features six circular wire holes. Amphenol Industrial Part Number C10-060718-001 measures approximately 3/4 inch in diameter and 1/2 inch in length and features six circular wire holes. Amphenol Industrial Part Number C-10-074818-01S measures approximately 7/8 inch at its greatest diameter and 1 3/8 inch in total length and features 10 circular wire holes. Amphenol Industrial Part Number C-10-074817-10P measures approximately 1 inch in diameter and 5/8 inch in length and features four circular wire holes. Amphenol Industrial Part Number C-10-074818-10P measures approximately 7/8 inch in diameter and 5/8 inch in length and features four circular wire holes. The grommets are all said to be used to hold and separate electrically conductive wires in the assembly of connectors, switches and wiring harnesses. They help organize and guide the wires and protect the wires against abrasion and pulling, providing strain relief. You have indicated that the grommets will be imported from Mexico, China, or other countries with which the United States has Normal Trade Relations. The samples are being returned.
You suggest classification in subheading 8546.90, Harmonized Tariff Schedule of the United States (HTSUS), as electrical insulators. Classification of merchandise under the HTSUS is governed by the General Rules of Interpretation (GRIs) taken in order. GRI 1 requires that classification be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. Section XVI note 1(a) states that the section “does not cover…other articles of a kind used in machinery or mechanical or electrical appliances or for other technical uses, of vulcanized rubber other than hard rubber (heading 4016).” Since the grommets are articles of vulcanized rubber other than hard rubber, described in heading 4016, they are precluded by that legal note from classification in any of the provisions of Section XVI, including subheading 8546.90.
The applicable subheading for the polychloroprene grommets will be 4016.99.6050, HTSUS, which provides for other articles of vulcanized rubber other than hard rubber: other: other. The general rate of duty will be 2.5 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 Joan Mazzola at (646) 733-3023.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division