CLA-2-85:OT:RR:NC:N2:220
Patricia Goodwin
Future Electronics
4150 Old Airways Blvd.
Southaven, MS 38671
RE: The tariff classification of electrical connectors from Switzerland and a threaded retaining ring from the United States
Dear Ms. Goodwin:
In your letter dated May 4, 2018 you requested a tariff classification ruling.
There are three items that have been submitted for our review. You state that you operate three global distribution centers located in the United States, Germany, and Singapore, and that the components subject to this ruling request are housed in these distribution centers and are frequently transferred between each location as required. You also state the subject goods, held at all three global distribution centers, are shipped directly to the customer as required.
The first item under consideration is an electrical connector identified as the Power Entry Modules with Line Filter, PN 5120.5070.0. Based on the information provided, the connector consists of a metal housing and a male 3-prong receptacle and is intended to be mounted to a panel. This panel mount electrical connector is equipped with an internal electrical filter which is used to provide capacitive decoupling between the connector's body and the panel, thereby providing electromagnetic interference (EMI) emissions to be shunted to the chassis ground. The filtering process does not alter or convert the electricity supplied to the panel and only provides a shield-to-ground connection.
The second item under consideration is identified as the Power Entry Modules without Line Filter, PN 6421.0053.12. Based on the information provided, this connector assembly consists of a printed circuit board (PCB) base having three power terminals for a wired connection. Mounted onto the PCB is one male 3-prong connector and one female 3-prong connector, each in its own plastic molded base. The mounted connectors are said to be modular and are soldered onto the PCB. This connector assembly is intended to be mounted onto a panel for the purpose of supplying power to a cabinet or similar enclosure.
The third item under consideration is identified as the Clipmount Ring, PN RNG-268. This article is a threaded retaining ring for LED mounting hardware. These retainer rings are available in different diameters, which then secure and provide uniformity in the placement of panel lenses or light pipes. This instant article measures: 0.360 inches (outer diameter), 0.265 inches (inner diameter), and has a thickness of 0.160 inches. The ring is constructed from polypropylene plastic.
In your request, you suggest that the Power Entry Module with Line Filter is correctly classified under 8536.69.8000, Harmonized Tariff Schedule of the United States (HTSUS), as an “other” type of electrical connector. We disagree. As subheading 8536 specifically provides for rack and panel connectors, they will be classified accordingly.
The applicable subheading for the Power Entry Modules with Line Filter, PN 5120.5070.0 will be 8536.69.4030, HTSUS, which provides for “Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits (for example, switches, relays, fuses, surge suppressors, plugs, sockets, lamp-holders or other connectors, junction boxes) for a voltage not exceeding 1,000 V…: Lamp-holders, plugs, and sockets: Other: Coaxial connectors; cylindrical multicontact connectors; rack and panel connectors…: Rack and panel connectors.” The general rate of duty will be Free.
The applicable subheading for the Power Entry Modules without Line Filter, PN 6421.0053.12 will be 8537.10.9170, 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 general rate of duty will be 2.7 percent ad valorem.
The applicable subheading for the Clipmount Ring, PN RNG-268 will be 3926.90.9996, HTSUS, which provides for “Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other: Other.” The general rate of duty will be 5.3 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 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