CLA-2-85:OT:RR:NC:N1:109
Michael E. Roll
Attorney at Law
Pisani & Roll LLP
1875 Century Park East, Suite 600
Los Angeles, CA 90067
RE: The tariff classification of a connector termination/grounding kit from Canada
Dear Mr. Roll:
In your letter dated October 4, 2013, you requested a tariff classification ruling on behalf of you client, Pentair Thermal Management LLC.
The merchandise in question is known as a connector termination/grounding kit (PPAK). This item consists of two brass gland connectors, two brass self-threading pots, two assemblies which consist of spacer disks and insulating sleeves, two torque tags and sealing compound. The PPAK is used to terminate, insulate and seal the end of single and multi-conductor copper sheathed cables, preparing them for connection to an electrical box. It supports the cable, insulates it and allows for the physical connection to the junction box while also providing a grounding contact between the cable’s outer copper sheath and the metal of the electrical box. The spacer disks and insulating sleeves provide the necessary electrical insulating qualities to this item while allowing it to guide and physically hold the electrical cable in place. The PPAK kit does not facilitate or provide a mechanism for the actual electrical connection between the cables internal conductors and the electrical supply within the junction box.
You have proposed classification of this item within subheading 8536.90.8085, HTSUS, which provides for “Electrical apparatus for switching or protecting electrical circuits, or for making connection to or in electrical circuits…: Other apparatus: Other: Other.” While this item may act as a grounding connector between the cable’s copper sheath and the electrical box, it does not connect the cables internal conductors to the power supply within the junction box. It is our opinion that the electrical grounding function is a subsidiary function of this item when compared to its insulating and support functions. As such heading 8536 would be inapplicable.
The applicable subheading for the connector termination/grounding kit (PPAK) will be 8546.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Electrical insulators of any material: Other". The general rate of duty will be free.
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 Steven Pollichino at (646) 733-3008.
Sincerely,
Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division