CLA-2-85:OT:RR:NC:N4:120
Mr. David Freston
Control4
3612 West 1820 South
Salt Lake City, UT 84104
RE: The tariff classification of an electrical controller
Dear Mr. Freston:
In your letter dated February 9, 2016, you requested a tariff classification ruling.
The merchandise under consideration is referred to as the CardAccess™ Heavy-Duty Power Controller (HPC), model number HPC10A-ZP. This device is described as a high voltage power controller specifically designed for use with the Control4® wireless home automation system. The HPC is housed in a metal enclosure that measures 4.6 inches in height, 10.5 inches in width, and 2.2 inches in depth, and has an external antenna attached to it for receiving radio frequency (RF) signals from the Control4® host controller, which you refer to as the “brain” of the home automation system and which is not subject to this request.
The HPC controller consists of two 100-240 VAC 30A relays that controls motor loads, resistive loads, and ballast type loads. It also consists of four low-voltage dry contacts to support external dry contact sensors or hard-wired manual override controls that allow it to be used in a stand-alone mode independent of a Control4® host system.
In your request you suggested classification in subheading 8525.50.3040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for; “Transmission apparatus for radio-broadcasting or television, whether or not incorporating reception apparatus or sound recording or reproducing apparatus; television cameras, digital cameras and video camera recorders: Transmission apparatus: Television: Other: Other: Other.” However, this merchandise is not transmitting a television signal; therefore, it is precluded from being classified in subheading 8525.50.3040, HTSUS.
The applicable subheading for the CardAccess™ Heavy-Duty Power Controller, model number HPC10A-ZP will be 8537.10.9070, HTSUS, which provides for; “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Other.” The general rate of duty will be 2.7 percent ad valorem.
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,
Deborah C. Marinucci
Acting Director
National Commodity Specialist Division