CLA-2 CO:R:C:M 089016 AJS
Mr. Henry M. Haney
806 Eagle Ridge Dr.
Birmingham, AL 35242
RE: Electrical power connectors; high voltage oil-filled
instrument transformers; Heading 8504; Liquid dielectric
transformer; Subheading 8504.21.00; Subheading 8504.22.00;
Subheading 8504.23.00.
Dear Mr. Haney:
This is in reply to your letter of March 11, 1991,
requesting a tariff classification ruling under the Harmonized
Tariff Schedule of the United States Annotated (HTSUSA).
FACTS:
The articles at issue are electrical power connectors from
Mexico or India and instrument transformers from Spain. The
transformers are described as high voltage oil-filled instrument
transformers. The connectors are not adequately described in the
request. We require a more detailed description explaining
exactly what the connectors are, where and how they are used, and
exactly how they operate. We were unable to locate your phone
number, which is unlisted, and the Square D Company was unable to
identify the subject connectors when contacted. Until further
information is provided, we are unable to offer advice on this
portion of your request.
ISSUE:
What is the proper tariff classification of the subject
transformers.
-2-
LAW AND ANALYSIS:
Heading 8504, HTSUSA, provides for electrical transformers.
The subject transformers satisfy this description. They are
described as high voltage oil-filled instrument transformers.
Oil-filled transformers are a type of liquid dielectric
transformer (LDT). Subheading 8504.21.00, HTSUSA, provides for
LDTs having a power handling capacity not exceeding 650 kVA.
Subheading 8504.22.00, HTSUSA, provides for LDTs having a power
handling capacity exceeding 650 kVA but not exceeding 10,000 kVA.
Subheading 8504.23.00, HTSUSA, provides for LDTs having a power
handling capacity exceeding 10,000 kVA. The kVA measurement of
the subject transformers is not specified. Therefore, the proper
subheading for the subject transformers cannot be determined at
this time.
HOLDING:
The subject transformers are properly classifiable in the
appropriate above mentioned subheading, depending on their kVA
measurement. Each of these subheadings provide for a duty rate
of 2.4 percent ad valorem when products of Spain.
Sincerely,
John Durant, Director
Commercial Rulings Division