CLA-2-85:OT:RR:NC:N4:120
Aaron Marx
Crowell & Moring LLP
1001 Pennsylvania Avenue, NW
Washington, DC 20004
RE: The tariff classification of electrical control panels from Italy
Dear Mr. Marx:
In your letter dated August 9, 2016 you requested a tariff classification ruling on behalf of your client Southern Tube, LLC.
The merchandise under consideration is identified as the Tempering Furnace Area Main Control Desk, the Tempering Furnace Combustion Fan Control System, the Tempering Furnace Recirculation Fan Control System, the Tempering Furnace Entry Side Control System, and the Tempering Furnace Exit Side Control System. Each of the control panels are said to be components of the operator interface of a rolling mill and operate at less than 1,000 V.
The Tempering Furnace Area Main Control Desk is an operator control station that is comprised of pushbutton switches, circuit breakers, contact blocks, status indicators, keyboards, and cutouts for two human machine interface modules. The Tempering Furnace Area Main Control Desk communicates with the automation supervisory controller for the rolling mill operation via an onboard interface module and allows for the electrical control and monitoring of certain processes.
The Tempering Furnace Combustion Fan Control System is an operator control station that is comprised of illuminated pushbutton and selector switches and contact blocks mounted in a steel enclosure. The Tempering Furnace Combustion Fan Control System provides for the local and/or remote electrical control of the start and stop functions for the furnace fans.
The Tempering Furnace Recirculation Fan Control System is an operator control station that is comprised of illuminated pushbutton and selector switches and contact blocks mounted in a steel enclosure. There are four fans which are controlled with a start and stop pushbutton switch for each fan. The Tempering Furnace Recirculation Fan Control System provides for the local and/or remote electrical control of the start and stop functions for the furnace fans.
The Tempering Furnace Entry Side Control System is an operator control station that is comprised of illuminated pushbutton, selector, and keylock switches, contact blocks, joystick controllers, and status indicators which are installed in a pedestal mounted steel enclosure. The Tempering Furnace Entry Side Control System provides for the local and/or remote electrical control and the start and stop functions for the charging equipment and walking beam functions of the rolling mill.
The Tempering Furnace Exit Side Control System is an operator control station that is comprised of illuminated pushbutton, selector, and keylock switches, contact blocks, joystick controllers, and status indicators which are installed in a pedestal mounted steel enclosure. The Tempering Furnace Exit Side Control System provides for the local and/or remote electrical control and the start and stop functions for the discharging equipment and walking beam functions of the rolling mill.
The applicable subheading for subject control panels, as described above, will be 8537.10.9170, 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: Other.” The 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 the World Wide Web at https://hts.usitc.gov/current.
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,
Steven A. Mack
Director
National Commodity Specialist Division