CLA-2-85:OT:RR:NC:N1:112
B. Bahramian
President
Center for Technology Management
202 Halpine Walk Ct.
Rockville, Maryland 20851
RE: The tariff classification of LEDs mounted on aluminum strip - 1 inch x different lengths, a polycarbonate curved diffuser - 25 m/m diameter, an aluminum extrusion from tube lights to house LEDs, small plastic LED lead wire connectors, a DC power switch & dimmer from unspecified countries of origin
Dear Mr. Bahramian:
In your letter dated June 23, 2014, you requested a tariff classification ruling.
The items in question are designed to be components of tube lights using LED components and special housing to deliver 360 degree light beams (bi-directional throw of beams) to replace the existing fluorescent tubes in the market using a fraction of the energy. The finished products are light tubes or strip lights used in residential and commercial buildings.
The items identified as LEDs are mounted on aluminum strips measure 1 inch by different lengths (Part # 29.2).
The items identified as a polycarbonate curved diffuser, 25 m/m diameter (Part # 26.4), and an aluminum extrusion for tube lights to house LEDs (Part #27-T) are parts of tube lights using LED components.
The applicable subheading for the LEDs mounted on aluminum strips; 1 inch by different lengths (Part # 29.2) is 8543.70.7000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Other machines and apparatus: Electric luminescent lamps.” The general rate of duty will be 2%.
The applicable subheading for the polycarbonate curved diffuser, 25 m/m diameter (Part # 26.4), and the aluminum extrusion for tube lights to house LEDs (Part #27-T) will be 8543.90.8880, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Parts: Other: Other: Other: Other.” The general rate of duty will be 2.6%.
Your inquiry does not provide enough information for us to give classification rulings on DC Power Switches & Dimmers (Part # 30.5).
In regard to both the micro-switches and dimmers, please provide samples of both devices as imported in their housing/base.
Please provide a labeled, exploded-view diagram of all the internal and external components of both the micro-switches and dimmers.
Are there more than one switch and dimmer that are apparently incorporated into the same housing/base?
Where in the light tube is the housing or base that incorporates the micro-switches and dimmers located? Is it at the base of the tube light? If not, please explain. Is it an integral part of the light tube?
With respect to the dimmer, is the dimmer a wire-wound variable resistor or potentiometer or “other”? Also, please confirm if the dimmers are “rotary dimmers.”
With respect to the micro-switches, please explain what they are controlling or activating.
Are these switches the types of devices for making or breaking one or more circuits in which they are connected, or switching from one circuit to another (in other words are they turning on and off an electrical connection)?
Further, would this merchandise be considered a simple switch consisting of two or more contacts mounted within an insulating structure and arranged so that they can be moved into and out of contact with each other by a suitable operating mechanism?
Are the micro-switches considered to be electronic AC switches consisting of optically coupled input and output circuits (insulated thyristor AC switches); or electronic switches, including temperature-protected switches, consisting of a transistor and a logic chip (chip-on-chip technology); or electromechanical snap-action switches for a current not exceeding 11 amps?
Are these micro-switches equipped with two or more apparatus of heading 8535 or 8536, Harmonized Tariff Schedule of the United States, for the electric control and distribution of electricity, such as switches, relays, fuses, surge suppressors, plugs, sockets, lamp-holders and other connectors, and junction boxes?
If these switches function as controllers, can they be considered “programmable controllers,” which are digital apparatus using programmable memory for the storage of instructions for implementing specific functions, such as logic, sequencing, timing, counting and arithmetic, to control, through digital and analog input/output modules, various machines? If so, please explain how they are programmable.
In layman’s terms, please explain how they (the micro-switches and dimmers) function and provide an operator’s manual, if available.
What is the function and relationship between the micro-switches and the dimmers, which are apparently incorporated in the same housing?
Your inquiry does not provide enough information for us to give a classification ruling on small plastic LED wire connectors (Part #30.1).
Please provide samples of the small plastic LED lead wire connectors, part number 30.1.
Please identify the types of connectors being imported, e.g., coaxial connectors; cylindrical multi-contact connectors; rack and panel connectors; printed circuit connectors; ribbon or flat cable connectors; or connectors for optical fibers, optical fiber bundles or cables.
Your request for a classification ruling should also include whether the connectors are attached to a cable at the time of importation.
When this information is available, you may wish to consider resubmission of your request. If you decide to resubmit your request, please include all of the material that we have returned to you.
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 Karl Moosbrugger at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division