CLA-2-90:OT:RR:NC:4:414
TARIFF NOS.: 9014.20.2000; 9014.90.6000
Ms. Nicole L. Mulligan
UPS Supply Chain Solutions
140 Thad Johnson Road, Unit 3
Ottawa, ON K4R 1V9
Canada
RE: The tariff classification of Inertial Measurement Units and Enclosures for Inertial Measurement Units exported from Canada
Dear Ms. Mulligan:
In your letter dated March 8, 2010, you requested a tariff classification ruling on behalf of NovAtel, Inc.
In your submission, you describe two Inertial Measurement Units (IMUs), the IMU-HG and the IMU-LN200. You state that an IMU “is the main component of inertial guidance systems used in air, space, and watercraft, including guided missiles. An IMU works by sensing motion – including the type, rate, and direction of that motion – using a combination of accelerometers and gyroscopes. The data collected from these sensors allows a computer to track a craft’s position, using a method known as dead reckoning.” Most IMUs contain three accelerometers and three gyroscopes. The accelerometers measure inertial acceleration (also known as G-forces), while the gyroscopes measure rotational position. An IMU works by detecting the current rate of acceleration, as well as changes in rotational attributes, including pitch, roll and yaw. This data is fed into a computer, which calculates the current speed and position, given a known initial speed and position.
The IMU-HG and the IMU-LN200 both operate along the same principles; however, they utilize different sensor systems. The IMU-HG contains a Honeywell HG1700 inertial measurement unit, which is described as a tactical grade IMU containing ring laser gyros and servo accelerometers. The IMU-LN200 contains a Northrop Grumman LN200 inertial measurement unit, which is also described as a tactical grade IMU, this one containing closed-loop fiber optic gyros and solid-state silicon accelerometers.
As stated above, both IMUs work by detecting the rate of acceleration of the craft in which they are installed, as well as changes in rotational attributes (such as pitch, role, and yaw). The data is used to calculate the current speed and position of the craft. The accelerometers and the gyroscopes contained in the IMUs are equally important in determining this data.
The IMU-HG and the IMU-LN200 handle the power needs of their respective sensor packages by means of a 9-28 volt power input, and they have the capability to send the speed and position data collected by the sensors to other NovAtel navigational devices. Based on the information you have provided, the IMU-HG and the IMU-LN200 are designed to be used in conjunction with a GPS-capable navigation system. A separate device would combine the information taken by both systems and blend the data in order to obtain the most accurate position, velocity, and attitude information. Neither the IMU-HG nor the IMU-LN200 contains their own embedded GPS device.
There are specially designed metal enclosures for the IMUs. The enclosures are part numbers IMU-H00 and IMU-LN000. You state that there are times when the enclosures will be shipped separately from the IMUs. The enclosures are specially fitted to accommodate the IMUs, and are incapable of serving any other purpose. The empty enclosures have no functionality without the IMUs installed, but they do contain a PCB power interface board. You suggest that the enclosures, when shipped separately, should be classified as a part of the IMUs.
You propose classifying the IMU-HG and the IMU-LN200 under 9014.20.8080, HTSUS, which provides for non-optical, non-electrical navigational instruments and appliances for aeronautical or space navigation. That heading would not apply to either device. It is clear from your description that both IMUs are electrical. Furthermore, both IMUs incorporate optical elements that are not subsidiary to the proper functioning of the IMUS, specifically the optical elements incorporated in the ring laser gyroscopes and in the closed-loop fiber optic gyroscopes.
You propose classifying the enclosures, part numbers IMU-H00 and IMU-LN000, under 9014.20.8080, HTSUS; however we believe you meant to propose 9014.90.2080, HTSUS, which provides for parts and accessories of articles covered by 9014.20.80, HTSUS. The IMU-HG and IMU-LN200 are not classifiable under 9014.20.8080, HTSUS. Accordingly, the parts are not classified under 9014.90.2080, HTSUS.
The applicable subheading for the IMU-HG and the IMU-LN200 will be 9014.20.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for instruments and appliances for aeronautical or space navigation (other than compasses): optical instruments and appliances. The rate of duty will be 2.8 percent ad valorem.
The applicable subheading for the enclosures, part numbers IMU-H00 and IMU-LN000, will be 9014.90.6000, which provides for instruments and appliances for aeronautical or space navigation (other than compasses): parts and accessories: other. The rate of duty will be free.
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 on World Wide Web at http://www.usitc.gov/tata/hts/.
This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Barbara Kiefer at (646) 733-3019.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division