CLA-2-85:OT:RR:NC:N2:220
Julio De Jesus Marin
Glamar Solar Inc.
PO Box 421
Jayuya, PR 00664
RE: The tariff classification of electrical inverters and chargers from China
Dear Mr. Marin:
In your letter dated September 30, 2019 you requested a tariff classification ruling.
The first item under consideration is referred to as the DC/AC, AC/DC Inverter/Charger (Inverter Charger), which is described as a pure sine wave combined power inverter and electrical charger. The Inverter/Charger comes in various models ranging from an output of 1kW to 12kW and consists of an enclosure containing the rectifying circuitry, cooling fans, input and output terminals, circuit breakers, and a front panel status liquid crystal display (LCD). There are two operating modes for the Inverter/Charger that are identified as “inverter mode” and “charge mode”, where the device supplies power directly to AC loads in inverter mode and monitors and controls the charging of batteries in charger mode. You state that the Inverter/Charger is intended to be connected to a photovoltaic generating system for the purpose of charging storage batteries and converting the DC electricity to AC.
The second item under consideration is referred to as the MMPT Solar Controller (Controller), which is described as a controller for charging various types of batteries and a static converter that supplies DC voltage directly to external devices. The Controller comes in two models, 40A and 60A, and consists of an enclosure containing the rectifying circuitry, cooling fans, input and output terminals, and a front panel status LCD. You state that the Controller is intended to be used with photovoltaic generating systems for the purpose of charging storage batteries.
The applicable subheading for the DC/AC, AC/DC Inverter/Charger will be 8504.40.9570, HTSUS, which provides for “Electric transformers, static converters and inductors…: Static converters: Other: Inverters.” The general rate of duty will be Free.
The applicable subheading for the MMPT Solar Controller will be 8504.40.9580, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical transformers, static converters (for example, rectifiers) and inductors; parts thereof: Static converters: Other: Other.” The general rate of duty will be Free.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 8504.40.9570 and 8504.40.9580, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheadings 8504.40.9570 and 8504.40.9580, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at:
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions https://www.cbp.gov/trade/remedies/301-certain-products-china
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