CLA-2-85:OT:RR:NC:N2:220
Rachael Barnes
TE Connectivity
2801 Fulling Mill Road
Middletown, PA 17057
RE: The tariff classification of disconnect plugs and receptacle from Mexico
Dear Ms. Barnes:
In your letter dated Jun 28, 2022, you requested a tariff classification ruling.
There are three items under consideration that you refer to as Manual Service Disconnects (MSDs). The first item is identified as the MSD Plug Assembly with Fuse, Item Number 1-2103172-8, which consists of consists of molded plastic inner and outer plug housing, a molded plastic lever and lever release, a silicone seal, two copper bus bars, two brass shorting bars, a fuse, and threaded steel fasteners. You state that the plug assembly is shipped as a single piece and is intended to mate with an electrical receptacle from the vehicle battery pack.
The second item is identified as the MSD Plug Assembly with Shunt, Item Number 1-2103172-7, which consists of molded plastic plug inner and outer housing, a molded plastic lever and lever release, a silicone seal, four brass shorting bars, and one copper shunt. You state that the plug assembly is shipped as a single piece and is intended to mate with the receptacle assembly protruding from the vehicle battery pack.
The third item is identified as the MSD Receptacle, Item Number 1-1587987-5, which consists of a molded plastic receptacle inner and outer housing, a silicone seal, twelve silver plated copper bus contacts, two copper bus bars, two aluminum overstress bars, four brass threaded inserts, and threaded steel fasteners. The receptacle assembly is shipped as one piece.
In your request, you suggest the subject MSDs are properly classified under subheading 8536.30.8000, Harmonized Tariff Schedule of the United States (HTSUS), as electrical protection apparatus. We disagree.
The MSDs under consideration here provide an electrical connection to high voltage vehicle power systems and/or battery banks. The presence of a fuse, with regard to Item Number 1-2103172-8, or the insulative properties of the molded housings for each of the MSDs, does not diminish the principal function of electrical connection, which each of the devices provide. As such, subheading 8536.30.8000, HTSUS, is not appropriate.
The applicable subheading for the MSD Plug Assembly with Fuse, Item Number 1-2103172-8, the MSD Plug Assembly with Shunt, Item Number 1-2103172-7, and the MSD Receptacle, Item Number 1-1587987-5, will be 8536.69.8000, HTSUS, which provides for “Electrical apparatus…for making connections to or in electrical circuits…: Lamp-holders, plugs and sockets: Other: Other.” The general 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