CLA-2-84:OT:RR:NC:N1:405

Tina Tang
Beckman Coulter, Inc.
250 S. Kraemer Boulevard
Brea, CA 92821

RE: The tariff classification of parts of a centrifuge system from China

Dear Ms. Tang:

In your letter dated October 17, 2016, you requested a tariff classification ruling.

The three items under consideration are described as precision cut hardware parts for centrifuge systems. The products in question are identified as the Interlock, Pedal (P/N 363175), the EMI filter cover (P/N 363267), and the Plate, Elutriator Port (P/N 366565). You indicate that all three items are formed from cold rolled sheet steel, laser cut, shaped, and painted for the express purpose of being incorporated into Beckman Avanti J series centrifuge systems.

The Interlock, Pedal (P/N 363175) is a component of the foot pedal interlock controller assembly in all Avanti J20, J30, and J-HC series centrifuges. The centrifuges incorporate a foot pedal device that enables a user to open and close the centrifuge door. Without the part at issue, the foot pedal device would not function properly, and a user would not be able to open and close the door to the centrifuge.

The EMI filter cover (P/N: 363267) is a specially shaped steel cover designed be placed over the EMI filter devices in all Avanti J26 and J30 series centrifuges. The purpose of each centrifuge’s EMI filter device is to reduce electromagnetic interference, and this cover serves to enclose that device. The filter cover is incorporated into the centrifuge to ensure that it can operate within the requisite safety standards and compliance requirements.

The Plate, Elutriator Port (P/N: 366565) is a component found just outside the elutriator rotors of Avanti J26 centrifuges. Different types of rotors can be used in the centrifuge, depending on the separation requirements of a given sample. The Plate, Elutriator Port is an integral component of the centrifuge that serves to support the centrifuge’s door when rotors are being placed and tested.

You suggest classification of the three components at issue in subheading 8421.91.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of centrifuges. Based on the information provided, all of the products at issue are specially designed for use in Avanti J series centrifuges, and are not suitable for any other purpose. Additionally, without these parts the centrifuges in question would not be able to safely operate within their established parameters. As the components in question are solely intended to be incorporated into centrifuges, and are not more specifically provided for elsewhere in the HTSUS, they are properly classified as parts of a centrifuges in subheading 8421.91.

The applicable subheading for the Interlock, Pedal, the EMI filter cover, and the Plate, Elutriator Port will be 8421.91.6000, HTSUS, which provides for Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Parts: Of centrifuges, including centrifugal drivers: 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 https://hts.usitc.gov/current.

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 Evan Conceicao at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division