CLA-2-85:OT:RR:NC:N4:120
Mr. Al Moon
Danfoss, LLC
11655 Crossroads Circle
Baltimore, MD 21220
RE: The tariff classification of electronic refrigeration controllers from Denmark and China
Dear Mr. Moon:
In your letter dated October 1, 2015 you requested a tariff classification ruling.
The subject merchandise identified as ERC-101, EKC- 102 and AK-CC210, are multi-purpose electronic controllers for use in refrigeration applications. Each device has a power supply rating of 100-240V and features an LED display with buttons for control, settings manipulation, and programming. These microprocessor based devices are programmable using the front panel buttons, or via a USB connection in conjunction with the proprietary software “Danfoss KoolProg”. The internal printed circuit board assembly contains the microprocessor, and memory to store the operating instructions, necessary to independently manage the refrigerator compressors, fans, alarms, or other devices connected to the controller’s outputs.
The subject controllers are intended to be installed onto the front panel of a refrigerator or cooler to govern the internal climate by controlling the operation of the compressors and fans. They have inputs for sensors that support various functions such as cabinet air temperature, evaporator temperature and condenser temperature, and an output connector for a digitally controlled on/off compressor relay. You state that no sensors or other attachments are included at the time of importation.
The applicable subheading for the ERC-101, EKC- 102 and AK-CC210 programmable controllers will be 8537.10.9060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or the distribution of electricity, …: For a voltage not exceeding 1,000 V: Other: Other: Programmable controllers. The general rate of duty will be 2.7 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 Karl Moosbrugger at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division