CLA-2-85:OT:RR:NC:N2:220
Cynthia Benway
Taco, Inc.
1160 Cranston Street
Cranston, RH 02920
RE: The tariff classification of plastic covers from Italy
Dear Ms. Benway:
In your letter dated July 8, 2019 you requested a tariff classification ruling.
The merchandise under consideration is identified as the Base Cover, Item #198-3247, and the Keypad, Item #198-3248, which are described as being outer components to an electric motor controller. The motor controller consists of electrical components and a printed circuit board assembly, a digital display, and three control switches. The finished controller, while not subject to this request, is said to electrically control the speed of an attached circulator pump motor.
The Base Cover under consideration is made from a flame retardant plastic resin that is specifically molded to protectively cover the motor controller printed circuit board assembly (PCBA). The cover is injection molded and measures approximately 2 1/2 inches in width by 1 3/8 inches in length. This protective cover is placed over the control box that houses the PCBA and electrical plugs, thereby protecting the electrical circuits while also preventing electric shock to users.
The Keypad under consideration is made from silicon rubber and is incorporated into the front of the controller housing in order to provide access to control switches. The Keypad cover allows users to apply pressure to the Keypad and operating mechanism residing underneath. You state that the Keypad does not incorporate any electrical components and merely acts as the protective cover for the switches. In use, when the user pushes the silicon cover it depresses a switch operator peg that makes the connection on the control board.
The applicable subheading for the Base Cover, Item #198-3247, and the Keypad, Item #198-3248, will be 8504.90.9690, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical transformers, static converters (for example, rectifiers) and inductors; parts thereof: Parts: Other: Other: Other parts: Other”. The general 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 the 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 Karl Moosbrugger at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division