CLA-2-85:OT:RR:NC:N1:112
B. Bahramian
President
Center for Technology Management
202 Halpine Walk Ct.
Rockville, Maryland 20851
RE: The tariff classification of a Polycarbonate Curved Diffuser, Aluminum Extrusion for Tube Lights, LEDs mounted on Aluminum strip, crimp wire connectors, and a DC power switch and dimmer from an undisclosed country
Dear Mr. Bahramian:
In your letter dated July 30, 2014, you requested a tariff classification ruling.
There are five items under consideration in your ruling request:
Part # 26.4 and is described as a “Polycarbonate Curved Diffuser, 25 mm diameter”. This item is a pre-formed light diffusing lens, of various lengths, and is intended to be fitted to the extruded aluminum frame. The diffuser is 1 millimeter in thickness and constructed of frosted acrylic. This item has been previously addressed in NY Ruling N254740.
Part # 27-T is described as an “Aluminum Extrusion for the Tube Lights, to house LEDs”. The aluminum extrusion is also part of the LED tube lamp and forms the base. The LED light strips and acrylic diffusers are affixed to the aluminum frame, which also acts as a heat sink for heat dissipation. This item has been previously addressed in NY Ruling N254740.
Part # 29.2 is described as “LEDs mounted on Aluminum Strip; 1” x different lengths”. This item has been previously addressed in NY Ruling N254740.
Part # 30.1 is described as “Small plastic LED Lead wire connectors”. Within the open end, they contain a metallic crimping device. These connectors are used to fasten two or more electrical conductors (wire) together. The electrical wires would be inserted into the connector and using a crimping tool, the connector would be crimped around the wires.
Part #30.5 is described as “DC Power Switch & Dimmer”. Because there are two distinct items having the same part number, they will be further identified as “Part #30.5 Power Switch” and “Part #30.5 Dimmer”. Part #30.5 Power Switch is described as a Micro DC power switch, which is a rocker style on/off switch.
Your inquiry does not provide enough information for us to provide a classification ruling on Part # 30.5 Dimmer. When this information is available, you may wish to consider resubmission of your request. Please refer to the information previously requested in NY N254740. If you decide to resubmit your request, please provide the following:
What type of resistor or rheostat is the dimmer, (fixed, wire wound, variable)?
What is the dimmer constructed of, (carbon, carbon composition, carbon film, metal oxide, cermet, metal glaze) and what is the maximum power rating in Watts?
After importation, you state the diffuser, mounted LEDs, and aluminum frame will be assembled into a T-8 style LED tube lamp, your Product #3.9, which is intended to be installed in a residential or commercial buildings and also ruled upon in NY 254740.
As noted in in NY 254740, the applicable subheading for the polycarbonate curved diffuser, 25 m/m diameter (Part # 26.4), and the aluminum extrusion for tube lights to house LEDs (Part # 27-T) will be 8543.90.8880, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Parts: Other: Other: Other: Other.” The general rate of duty will be 2.6%.
As noted in NY 254740, the applicable subheading for the LEDs mounted on Aluminum Strip; 1” x different lengths (Part # 29.2) is 8543.70.7000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Other machines and apparatus: Electric luminescent lamps.” The general rate of duty will be 2%.
The applicable subheading for the Small plastic LED Lead wire connectors (Part # 30.1) will be 8536.90.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits…for a voltage not exceeding 1,000 V: Other apparatus: Terminals, electrical splices and electrical couplings; wafer probers." The general rate of duty will be Free.
The applicable subheading for Part #30.5 Power Switch 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 (for example, switches…), for a voltage not exceeding 1,000 V: Other switches: Other: Other: Other.” The general rate of duty will be 2.7 percent ad valorem.
The “Aluminum Extrusion for the Tube Lights” (Part # 27-T) may be subject to antidumping duties or countervailing duties. Written decisions regarding the scope of AD/CVD orders are issued by the Import Administration in the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection. You can contact them at http://www.trade.gov/ia/ (click on “Contact Us”). For your information, you can view a list of current AD/CVD cases at the United States International Trade Commission website at http://www.usitc.gov (click on “Antidumping and countervailing duty investigations”), and you can search AD/CVD deposit and liquidation messages using the AD/CVD Search tool at http://adcvd.cbp.dhs.gov/.
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 Karl Moosbrugger at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division