CLA-2-85:OT:RR:NC:N2:220
Tony Mikami
NGT Controls
21092 Bake Parkway, 104
Lake Forest, CA 92630
RE: The tariff classification of a printed circuit assembly with a bimetal thermostat from Japan
Dear Mr. Mikami:
In your letter dated April 1, 2026, you requested a tariff classification ruling.
The product at issue is described as a printed circuit assembly with a bimetal thermostat, identified by model
number 03EN6922B121. The subject device includes a plastic housing, a circuit board with a relay,
capacitor, and other electrical components, terminals, and a bimetal thermal switch. The bimetal switch is
comprised of two metals bonded together in the form of a strip or disc. When the metals are heated, the
difference in expansion rates cause the metal to bend or snap when a certain temperature is reached. This
action either opens or closes an electrical circuit by sending a signal to the printed circuit assembly. The
subject switch device is used in electrical duct heaters or unitary electric heaters acting as a protection against
excessive heat.
The applicable subheading for the printed circuit assembly with a bimetal thermostat will be 8537.10.9170,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Boards, panels, consoles,
desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or
the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Other”. The general rate
of duty will be 2.7 percent ad valorem.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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 Gary Chaffee at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division