CLA-2-86:S:N:N1:106-860364
Ms. Liz Miressi
Hitachi America, Ltd.
50 Prospect Avenue
Tarrytown, NY 10591-4698
RE: The tariff classification of railway equipment from Japan
Dear Ms. Miressi:
In your letter dated February 6, 1991 you requested a tariff
classification ruling. You have submitted descriptive
literature.
The imported product is an Hitachi VVVF AC Inverter Drive
Propulsion System. Your information states that the system
consists of two essential parts, the VVVF inverter control
equipment and the traction motor. The VVVF inverter control
equipment consists of an inverter and a gate controller. The
inverter consists of U-phase, V-phase and W-phase, each
incorporating a filter capacitor to convert DC current to three-
phase AC current. It also contains GTO thyristors which turn the
current on and off. A nonsubmerged element type cooing unit is
installed for each phase of the inverter. The gate control logic
incorporates a unit generating the binary signal of the gate turn
off (GTO) thyristor by means of a 16 bit microprocessor.
The traction motor is a 3-phase squirrel cage AC induction
motor. It uses a 200c insulation system and includes L-packed
type bearings, a gear unit and a gear unit coupling. Your
product information states the traction motor as having 170 kW.
Depending on the customer's requirements, the motor can range
from 135 kW up to 170 kW. The VVVF inverter drive propulsion
system is used for railway rolling stock and is recognized as an
alternative driving system to the chopper controlled DC traction
motor.
It is your opinion the VVVF inverter control equipment is
classified in subheading 8504.40.0040, Harmonized Tariff Schedule
(HTS), and the traction motor is classified in subheading
8501.53.4080, HTS. The Notes to Section XVI, HTS, (which
includes chapter 85) excludes articles of Section XVII, in which
the rolling stock provisions fall. Therefore, the imported
product cannot be classified in chapter 85.
The applicable subheading for the Hitachi VVVF AC Inverter
Drive Propulsion System will be 8607.19.9000, Harmonized Tariff
Schedule of the United States (HTS), which provides for parts of
truck assemblies of headings 8605 or 8606 (railway rolling
stock). The rate of duty will be 3.9 percent ad valorem.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport