CLA-2-85:OT:RR:NC:N1:109

Ms. Lucy Holt Beckhoff Automation LLC 13130 Dakota Ave. Savage, MN 55378 RE:  The tariff classification of EtherCAT® I/O terminals from Germany Dear Ms. Holt: In your letter dated September 16, 2014, you requested a tariff classification ruling. There are five items concerned; they are described as EtherCAT® controller/device terminals, couplers, and an end terminal. EtherCAT® is the term used to describe an Ethernet network used for control automation technology. These five devices are used to facilitate the transfer of data between various electronic devices (sensors and actuators) and a computer which is responsible for the monitoring and control of those components. These EtherCAT® devices provide the computer with the digital information it needs to execute a specific monitoring and control function. They connect directly to a computer using Ethernet cables. In use, the input units receive signals from electronic devices (i.e. sensors and actuators), they convert those signals into a digital data format and then transmit those converted signals to a computer. The output units receive a data signal from a computer and convert it into an intelligible form for an external device to act upon. The first item is an EtherCAT® “Profinet RT” controller/device fieldbus terminal (model # EL6631). This device has a three port switch and connects the EtherCAT® (network) with up to fifteen “Profinet” input or output devices. It connects to the “Profinet” bus coupler (model # BK9103) via an Ethernet cable and transmits data quickly within the EtherCAT® network. The second item is an EtherCAT® “Profibus” master/slave fieldbus terminal (model #EL6731). This device also connects to the EtherCAT® network and transmits data within it, but at a slower rate. It connects to the “Profibus” bus coupler (model #BK3120) via an RS485 cable, and receives and transmits input and output signals from process level components in an electrically isolated form, to a higher-level automation unit. As a result of a special chip, the terminals are equipped with the latest technology for axis control and expanded diagnostic options. The third and fourth items are identified as the “Profinet” bus coupler (model #BK9103) and the “Profibus” economy plus bus coupler (model #BK3120), each of which connect to the “Profinet RT” and “Profibus” fieldbuses, respectively, via Ethernet and RS485 cables. They allow for the creation of more terminal rows (up to 64), and recognize the terminals to which they are connected. They also automatically perform the assignment of the digital and analog input and output signals to the words of the process image. By working together with the sensors and actuators, the result is less interference and increased productivity.

The fifth item is identified as a “K-Bus” end terminal (model #KL9010). This device is necessary for data exchange between the “Profinet” and “Profibus” fieldbus terminals and the “Profinet” and “Profibus” fieldbus couplers. The applicable subheading for the EtherCAT® Profinet RT and Profibus fieldbus terminals (model #’s EL6631 and EL6731), the Profinet and Profibus Bus Couplers (model #’s BK9103 and BK3120), and the K-Bus end terminal (model #KL9010) will be 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Telephone sets…; other apparatus for the transmission or reception of voice images or other data…: Other apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network): Machines for the reception, conversion and transmission or regeneration of voices, images or other data, including switching and routing apparatus: Other.” The 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: [email protected]. Sincerely,

Gwenn Klein Kirschner Director National Commodity Specialist Division