CLA-2-85:OT:RR:NC:N4:109
Eric Segal
Panasonic Corporation of North America
Two Riverfront Plaza – 9th Floor
Newark, NJ 07102
RE: The tariff classification of a Charge-Discharge Machine from Japan
Dear Mr. Sega:
In your letter dated March 4, 2016, you requested a tariff classification ruling.
The item concerned is referred to as a Charge-Discharge Machine (Model # PNLI GC1). This machine is used to charge and discharge lithium-ion batteries. The process involves putting the batteries through a precise charge/discharge process. As the batteries are put through these cycles the machine checks the battery performance for capacity and impedance and also gathers, analyzes and records data on the results. The machine is designed to charge and check the electrical quantities of the battery.
In use, trays containing batteries are loaded into the machine. The machine uses its power source to apply a charge to the batteries, and then also discharge the batteries, according to specific voltages, time durations and capacities. This machine uses a metering system to gather, measure and record voltage and amperage results. The metering system uploads results to a main computer system via a network connection. At the end of the process this machine provides the final charge to the batteries, making them ready for use.
The Charge-Discharge Machine incorporates two main functions, the charging/discharging of the batteries and a metering system to check and record the performance of the batteries,
It is the opinion of this office that the principal function of this machine is imparted by its ability to provide a charge to a battery(s). The process of charging a battery often involves a charge\discharge function as well as a metering or performance measuring function. Even smaller automobile battery charges have a metering system that runs a battery diagnostic before applying the final charge. The charging function provides the final user with the desired result, a charged battery. In addition, without the ability to charge the battery, there would be no reason for the metering system. The metering system insures that the batteries are safely and efficiently charged.
You suggest classification of the subject product in subheading 9030.39.0100, HTSUS, as Oscilloscopes, spectrum analyzers and other instruments and apparatus for measuring or checking electrical quantities, excluding meters of heading 9028; instruments and apparatus for measuring or detecting alpha, beta, gamma, X-ray, cosmic or other ionizing radiations; parts and accessories thereof: Other instruments and apparatus, for measuring or checking voltage, current, resistance, power: Other, with a recording device. However, since it has been determined that the principal function is imparted by the charging aspect of the machine, rather than its measuring/checking function, classification in Chapter 90 is precluded.
The applicable subheading for the Charge-Discharge Machine (Model # PNLI GC1) will be 8504.40.9550, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical transformers and static converters…: Other: Rectifiers and rectifying apparatus: Other.” The general rate of duty will be 1.5%.
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 Steven Pollichino at [email protected].
Sincerely,
Deborah C. Marinucci
Acting Director
National Commodity Specialist Division