CLA-2-84:OT:RR:NC:N1:102
Gregory S. Snider
Generator Inc.
1206 Mazeland Drive
Bel Air, MD 21015
RE: The tariff classification of a control panel from China.
Dear Mr. Snider:
In your letter dated April 15, 2015 you requested a tariff classification ruling.
Control Panel, part number 87404, is a device that connects to an Emergency Water Tank Assembly. Together, the Control Panel and Water Tank Assembly provide potable water during power outages. The Control Panel is housed in a plastic casing and includes an air compressor, a check valve, two electric relays, a 12 volt lead acid battery, a fuse block, a solenoid, a trickle charger, a pressure switch and a manifold. This device plugs into a 12 volt household receptacle, enabling the battery to charge and the electric relays to monitor the electrical service. Upon the occurrence of a power outage, the compressor inflates air into the internal rubber bladders of the water tanks via an air pressure line. The Control Panel continuously maintains a range of 30 to 50psi of air pressure within the water tanks. Once electricity is restored, the pressurized air is expelled from the storage tanks, allowing the tanks to fill to capacity with water.
The classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is governed by the General Rules of Interpretation ("GRIs"), taken in order. GRI 1 requires that classification be determined according to the terms of the headings and any relative section or chapter notes. Legal Note 4 to Section XVI, in pertinent part, states where a machine consists of individual components intended to contribute together to a clearly defined function covered by one of the headings in chapter 84, then the whole falls to be classified in the heading appropriate to that function.
The Control Panel consists of individual components that contribute to the function of providing compressed air into the water tank assembly. HTSUS heading 8414 includes air compressors that provide pressured air to a machine or apparatus. Thus, the applicable subheading for the Control Panel, part number 87404, will be 8414.80.1680, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Air or vacuum pumps, air or gas compressors…Other; Air Compressors; Other; 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 Sandra Martinez at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division