CLA-2-85:OT:RR:NC:N2:209
Samantha De La Cerda
Kemet Electronics Corporation
2835 Kemet Way
Simpsonville, SC 29681
RE: The tariff classification of a capacitor part from Bulgaria
Dear Ms. De La Cerda:
In your letter dated October 31, 2025, you requested a tariff classification ruling.
The item concerned is described as a precursor wound element, that is used in the manufacture of a capacitor.
The wound element is a partially processed component used in the production of film capacitors for energy
storage and power electronics applications. It is composed of metallized plastic films. At time of importation
into the United States, this item has undergone the initial three stages of the manufacturing process:
Winding of metallized plastic films into a compact cylindrical element - extremely thin dielectric films
are metallized on one side. These films, often just a few micrometers thick, are carefully tensioned and
wound in alternating layers resulting in a tightly wound roll that forms the structural core.
Metal spraying - the ends of the wound element are sprayed with a conductive metal, usually zinc or a
zinc-aluminum alloy, to form the electrode terminations.
Thermal stabilization - after the spraying process, the element undergoes a controlled thermal treatment
to improve the adhesion of the metallized layers and remove trapped air, thereby increasing the
mechanical stability of the element and ensuring proper bonding of the sprayed material.). This item
represents the structural core of the future capacitor.
Additional processing steps carried out after importation into the United States:
Mechanical cleaning - Residual particles and loose metal generated during spraying and thermal
processes are removed through mechanical cleaning.
Electrical clearing - A controlled overvoltage is applied to the dielectric layer to eliminate weak points
through a process known as electrical clearing. This operation deliberately 'burns out' microscopic
defects in the dielectric film, increasing dielectric strength and enhancing long-term reliability.
Element Assembly - The processed element is now assembled with additional internal components
required for integration into the final device. This may include internal leads, support structures, and
connection points necessary to ensure electrical continuity and mechanical stability.
Assembly into can - The wound element is inserted into its metallic can, which serves multiple
purposes: it provides mechanical protection, contributes to heat dissipation, and forms part of the
capacitor’s external connection system. Proper positioning and secure mounting of the element inside
the can are crucial to maintain mechanical stability and electrical integrity.
Electrical Testing Before Resin Filling
Resin Filling - The metallic can is filled with insulating resin, which encapsulates the internal element
and provides mechanical stability, environmental sealing, and protection against humidity, vibration,
and mechanical stress. The resin also enhances dielectric performance by preventing partial discharges
and stabilizing the internal structure.
Rotation for Resin Check - The components is rotated to ensure uniform distribution of the insulating
resin and to eliminate voids or trapped air that could compromise insulation performance.
Electrical/Visual Test, Marking, and Packaging - Comprehensive electrical and visual tests are carried
out to verify the capacitor’s performance characteristics, including capacitance, equivalent series
resistance (ESR), insulation resistance, and dielectric strength.
Final Quality Control - Final quality control ensures that all previous processes meet the required
technical standards and manufacturing specifications.
The applicable subheading for the precursor wound element will be 8532.90.0000, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for “Electrical capacitors, fixed, variable or
adjustable (pre-set); parts thereof: Parts”. The general rate of duty will be Free.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of the European
Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15
percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General
duty rate. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.02.20, in addition to subheading 8532.90.0000, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
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, please contact
National Import Specialist Steven Pollichino at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division