CLA-2-79:OT:RR:NC:N1:113

Mr. Ryan Supek
TE Connectivity
2800 Fulling Mill Road
Middletown, Pennsylvania 17057

RE: The tariff classification of Universal Power Module Keyed Guide Pins and Female Guide Modules from China

Dear Mr. Supek:

In your letter dated March 3, 2020, you requested a tariff classification ruling for Universal Power Module (UPM) Keyed Guide Pins and UPM Female Guide Modules. Drawings and Application Specification Documents were submitted for our review.

The subject merchandise is identified in your letter as the UPM Keyed Guide Pin (part number 5223985-6) and the UPM Female Guide Module (part number 5223957-3). The two items are used in the UPM connector system. UPM connectors are inserted onto printed circuit boards. The guide pin and female guide module are used to aid connector alignment during mating.

You stated that “The UPM Keyed Guide Pin is made of die cast zinc and plated with nickel. The guide pin is internally threaded on one end and must be secured to the pc board using a customer-supplied screw…The UPM Female Guide Module is made of die cast zinc with chromate conversion coating. The Female Guide Module must be seated using a force of approximately 89 N [20 lb.]; then secured using a customer-supplied screw.” You indicated that the guide pin or guide module “is not a connector since it does not conduct electricity, and it is not a connector part since it is not part of the actual UPM connectors. It is an optional accessory and is only used to assist with the blind mating of connectors.”

The applicable subheading for the UPM Keyed Guide Pins (part number 5223985-6) and the UPM Female Guide Modules (part number 5223957-3), will be 7907.00.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of zinc: other. The rate of duty will be 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 the World Wide Web at https://hts.usitc.gov/current.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 7907.00.6000, 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 subheading 7907.00.6000, 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 and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.

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 Ann Taub at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division