CLA-2-85:OT:RR:NC:1:110

Mr. John M. Peterson
Neville Peterson LLP
17 State Street - 19th Floor
New York, NY 10004

RE: The tariff classification of connector parts from China.

Dear Mr. Peterson:

In your letter dated October 29, 2012, you requested a tariff classification ruling, on behalf of your client Amphenol Optimize Manufacturing Co., Inc.

The items under consideration are identified as the Amphenol Aerospace Part Numbers ZP-7024-20A-BR, ZP-W-5324, ZP-5524-20A, ZP-41646-38L and ZP-3124-86M. Samples of the individual items and a connector incorporated with the parts were provided with your ruling request.

Amphenol Part Number ZP-7024-20A-BR is a plated aluminum coupling nut. It has an external diameter of 3 1/2 inches at its widest point, and features raised hexagonal tightening ridges on the outer surface. The inner surface of the adapter features a retaining ridge at its midpoint. It slides onto a conduit and is kept in place by a plug shell, which is designed to be screwed onto the edge of the conduit.

Amphenol Aerospace Part Number ZP-W-5324 is a cable clamp assembly made of aluminum. The cable clamp assembly is designed to be placed on the rear end of the cylindrical conductor as a rear end retainer. It is threaded on the inside and it is designed to be screwed onto, and made fast with, the back portion of the conduit. The part features a mounting onto which two clamps can be placed. When in place and tightened, the clamps form a circular hole through which a wire, cable or other conductor can be threaded, typically through a grommet.

Amphenol Part Number ZP-5524-20A is a "dust cover" used to cover the end of a cylindrical electrical connector when not in use. It is threaded on the outside at its open end, and features indentations on its inner side which allow it to be slipped into place over a conduit. Thereafter, the nut coupling can be tightened over the dust cover's outer caps.

Amphenol Part Number ZP-41646-38L is an electrical contact. It is composed of steel with two copper contact bands (Parts TMPC 4177-20C) assembled into the outer portion of the contact at one end. The copper band extends into the center of the contact, which measures approximately 1-1¼ inch in diameter. It is designed to be placed within a conduit and to make contact with an electrical component in order to complete a connection.

Amphenol Part Number ZP-3124-86M is a shaped electrical insulator made of injection molded plastics. It measures approximately 2-1/2 inches in diameter and it has a raised retaining ridge on its outer surface. The part is designed to be placed over one end of the electrical contact which, in turn, is designed to be placed into the conduit in the circular electrical connector.

The Amphenol Aerospace Part Numbers ZP-7024-20A-BR, ZP-W-5324, ZP-5524-20A, ZP-41646-38L and ZP-3124-86M will be imported separately and will be incorporated with other components to manufacture cylindrical electrical connectors after importation.

The applicable subheading for the Amphenol Aerospace Part Numbers ZP-7024-20A-BR, ZP-W-5324, ZP-5524-20A and ZP-41646-38L will be 8538.90.8080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Parts suitable for use solely or principally with the apparatus of heading 8535, 8536 or 8537: Other: Other: Other: Other: Other." The general rate of duty will be 3.5 percent ad valorem.

The applicable subheading for the Amphenol Aerospace Part Number ZP-3124-86M will be 8547.20.0000, HTSUS, which provides for insulating fittings for electrical machines, appliances or equipment…insulating fittings of plastics. 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 subheading 8538.90.8080, please contact National Import Specialist Hope Abada at (646) 733-3016. For issues regarding subheading 8547.20.0000, please contact National Import Specialist Steven Pollichino at (646) 733-3008.

Sincerely,

Thomas J. Russo
Director
National Commodity Specialist Division