CLA-2 CO:R:C:G 086223
Mr. Robert Blanc, Esq.
Associate General Counsel
Director Of Customs
General Instrument Corporation
125 Chubb Ave., P.O. Box 617
Lyndhurst, NJ 07071-0617
RE: Bridge Rectifier Diodes
Dear Mr. Blanc,
This responds to your correspondence dated December 22, 1989
in which you requested reconsideration of HQ Ruling 085540
(December 18, 1989). HQ Ruling 085540 determined the
classification of certain bridge rectifier diodes. Our ruling
follows.
FACTS:
The merchandise consists of the General Instrument series
KBPC6 Bridge Rectifier Diodes (BRD's). BRD's are comprised of
four discrete rectifier diodes connected into a bridge
configuration, some with mountings, housings and integral cooling
attachments. The articles have four terminals and an
asymmetrical voltage-current characteristic used for the purpose
of rectification. All the series KBPC6 BRD's are used for the
function of converting alternating current to direct current.
ISSUE:
Are the BRD's classified as Heading 8541 "similar
semiconductor devices", or as Heading 8504 static converters?
LAW AND ANALYSIS:
HQ Ruling 085540 (December 18, 1989) determined that BRD's
were classified as static converters in Heading 8504. The
-2-
importer's request for reconsideration suggests that if the BRD's
do not meet the Heading 8541 description for "diodes", then they
should be classified in Heading 8541 as "similar semiconductor
devices".
The BRD's under consideration are not classifiable as
Heading 8541 "similar semiconductor devices". The Explanatory
Notes to Heading 8541 provide that "similar semiconductor
devices" include thyristors, triacs, diacs, varactors, field
effect devices and Gunn effect devices. This list is
illustrative and the "similar semiconductor devices" listed
appear to be discrete devices and are not assemblies of devices
designed to perform a principal function which is specifically
described by another heading of the HTSUSA. A BRD's individual
diodes, if classified separately, might meet the Chapter 85 Note
5(A) definition for diodes and be classified in Heading 8541;
however, BRD assemblies are articles designed to perform a
principal function of rectifying alternating current to direct
current, a function specifically described by another Heading of
the HTSUSA, and do not fall in Heading 8541.
The BRD's under consideration are described by Heading 8504
as static converters. The Explanatory Notes to Heading 8504, p.
1338, provide that static converters are apparatus used to
convert electrical energy in order to adapt it for further use.
An assembly of diodes in a bridge configuration with four
terminals for the specific use of rectification is an apparatus
described as an electrical static converter. The BRD's are less
sophisticated than other converters described in the Explanatory
Notes to Heading 8504 in that they do not incorporate
transformers, induction coils, etc.; nevertheless, they are
described by Heading 8504 and fall in subheading 8504.40.00,
HTSUSA.
HOLDING:
HQ Ruling 085540 (December 18, 1989) correctly determined
that the General Instrument series KBPC6 Bridge Rectifier Diodes
are classified in subheading 8504.40.00 and is affirmed.
Sincerely,
Jerry Laderberg
Acting Director
Commercial Rulings Division