CLA-2-85:OT:RR:NC:N2:209
Mr. Derryl James
Yusen Logistics America
19001 Harborgate Way
Torrance, CA 90501
RE: The tariff classification of a solar panel junction box assembly from China
Dear Mr. James:
In your letter dated January 19, 2018, you requested a tariff classification ruling on behalf of your client Jinko Solar (U.S.) Industries Inc.
The item concerned is a junction box assembly for a solar panel. This assembly consists of a junction box which incorporates an internal diode, two lengths of electical cable which extend out of the junction box and two connectors on the end of each cable.
In use, this junction box would be attached to the rear side of a solar panel. It is electrically connected to the electrical leads of the panel. The diode in the junction box acts as a protective element and the cables with connectors are used to carry the current out of the panel. It is stated that the cables connect the solar panel to a solar power charging system.
You suggest classification under subheading 8536.90 of the 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: Other Apparatus." However, the Explanatory Notes for heading 8536 exclude plugs and sockets, etc., assembled with a length of wire and direct us to heading 8544. As such, heading 8536 would not be applicable.
Based on the exclusions cited above and the similarity between this assembly and the merchandise addressed in HQ H064919, we are of the opinion that heading 8544 would apply to this merdhandise.
The applicable subheading for the solar panel junction box assembly will be 8544.42.9090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Insulated wire, cable and other insulated electric conductors, whether or not fitted with connectors: Other electric conductors, for a voltage not exceeding 1,000 V: Fitted with connectors: Other: Other: Other." The general rate of duty will be 2.6% 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 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 Steven Pollichino at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division