CLA-2-85:OT:RR:NC:N2:85

Michael E. Murphy
Baker & McKenzie LLP
815 Connecticut Avenue, N.W.
Washington, DC 20006-4078

RE: The tariff classification of display lenses from China

Dear Mr. Murphy:

In your letter dated October 20, 2017, you requested a tariff classification ruling on behalf of your client, Tektronix, Inc.

There are two items concerned, both are passive display lenses for vacuum fluorescent displays ("VFDs"): model nos. 2000-304 and 2410-311. The lenses will be permanently incorporated into specific VFD modules, which, in turn, will be incorporated into Tektronix's test and measuring instruments.

The lenses are made of GE (Genuine) Lexan material, a polycarbonate of high impact strength, a thin layer of acrylic adhesive and polyester lamination. They are covered with a thin layer of protective low tack mask tape on the front; a thin layer of high tack masking film on the back; and contain a narrow strip of high bond strength adhesive along the edges on the back. The outer dimensions of both lens models are 42 mm x 162 mm.

Tektronix's passive display lenses are specifically designed to fit over the front exterior of the VFD module of Tektronix's measuring instruments. The passive display lenses are constructed to protect and hide the VFD's circuitry, and ensure that the data provided via the VFD technology is readable on the display lens in any lighting and temperature conditions. Each passive display lens is identifiable by specific part number, made to specifications, cut to size, and silk screened with Keithley' s logo (a Tektronix's brand) and the measuring instrument model number.

Tektronix's VFDs are limited use electrical displays that use vacuum fluorescent technology to display precision voltage, current sourcing and measurement data. This information is displayed in an alpha numeric format (illuminated numbers and text). Tektronix's VFD modules are designed to function as indicator panels. Indicator panels of this nature are provided for within heading 8531, Harmonized Tariff Schedule of the United States (HTSUS). The Passive Display Lenses would be considered parts of the VFD’s.

The applicable subheading for the passive display lenses: model nos. 2000-304 and 2410-311 will be 8531.90.9001, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric sound or visual signaling apparatus…: Parts: Other: Other.” The rate of duty will be 0.6%.

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 Steven Pollichino at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division