CLA-2-85:OT:RR:NC:N2:220
Christopher Mazuc
Tesota Overland
3412 W Red Bird Ct
Tucson, AZ 85745
RE: The tariff classification of printed circuit board (PCB) mounted terminal blocks from Germany
Dear Mr. Mazuc:
In your letter dated January 20, 2023, you requested a tariff classification ruling.
The first item under consideration is identified as the PCB Terminal Block, PN 2604-1102, which is described as a push-in, lever actuated terminal block having a plastic body and three termination sockets where solid and/or ferruled conductors can be inserted and clamped into position. The PCB Terminal Block, PN 2604-1102, is rated at 400 V and is equipped with electrical contacts where the device is soldered onto a PCB.
The second item under consideration is identified as the PCB Terminal Block, PN 2606-1102. Similar to the previous terminal block, PN 2606-1102 is also described as a push-in, lever actuated terminal block having a plastic body, three termination sockets, and electrical contacts on the bottom that allow for soldering onto a PCB. However, based on the supplied specifications, the PCB Terminal Block, PN 2606-1102, is stated to be rated at 630 V.
The third item under consideration is identified as the PCB Terminal Block, PN 2616-1102. Similar to the previous terminal blocks, PN 2616-1102 is also described as a push-in, lever actuated terminal block having a plastic body, three termination sockets, and electrical contacts on the bottom that allow for soldering onto a PCB. However, based on the supplied specifications, the PCB Terminal Block, PN 2616-1102, is stated to be rated at 320 V.
In your request, you suggest the subject terminal blocks are classifiable under subheading 8536.69.4040, Harmonized Tariff Schedule of the United States (HTSUS).
The General Rules of Interpretation (GRIs) to the HTSUS govern the classification of goods in the tariff schedule. GRI-1 states, in pertinent part, "For legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes . . . ." In addition, although not dispositive, the Explanatory Notes (ENs) to the Harmonized Commodity Description and Coding System represent the official interpretation of the tariff at the international level and facilitate classification under the HTSUS by offering guidance in understanding the scope of the headings and the GRIs.
The ENs to heading 8536, HTSUS, part (III), provides for apparatus for making connections to or in electrical circuits. Specifically, EN 85.36 (III)(B) describes terminals and terminal strips as follows:
These include small squares of insulating material fitted with electrical connectors (dominoes), terminals which are metal parts intended for the reception of conductors, and small metal parts designed to be fitted on the end of electrical wiring to facilitate electrical connection (spade terminals, crocodile clips, etc.).
Terminal strips consist of strips of insulating material fitted with a number of metal terminals or connectors to which electrical wiring can be fixed. The heading also covers tag strips or panels; these consist of a number of metal tags set in insulating material so that electrical wires can be soldered to them. Tag strips are used in radio or other electrical apparatus
The terminal blocks at issue here, which function to make electrical connections from a wire or other ferrule conductor to a PCB, utilize a quick lever style actuator instead of a screw down terminal. However, the subject electrical apparatus still function as a terminal blocks. Furthermore, we would note that neither the HTSUS nor the ENs prevent terminal blocks of this type from having the ability to attach to an electrical circuit via soldering to a PCB. It is the opinion of this office that the terminal blocks subject to this request are more accurately described elsewhere, and as such, we disagree with the suggested classification.
The applicable subheading for the PCB Terminal Blocks, PN 2604-1102, PN 2606-1102, and PN 2616-1102, will be 8536.90.4000, HTSUS, which provides for “Electric apparatus for switching or protecting electric circuits, or for making connections to or in electrical circuits…: Other apparatus: Terminals, electrical splices and electrical couplings; wafer probers.” The general rate of duty will be Free.
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