CLA-2-85:OT:RR:NC:N2:220
Sari Hurtig
Cinch Connectivity Solutions Inc.
1700 Finley Road
Lombard, IL 60148
RE: The tariff classification of a multi-jack electrical connector from China
Dear Ms. Hurtig:
In your letter dated August 11, 2020 you requested a tariff classification ruling.
The item under consideration is referred to as a multi-jack electrical connector, Part Number SS73100-046F, and is described as a stacked, dual row of RJ45 electrical sockets mounted together, where each row consists of six sockets and each socket contains 8 contact pins. The stacked connector is comprised of upper and lower rear assemblies, front, middle and rear shield, and is encased in a single thermoplastic housing. In use, the multi-jack electrical connector assembly is soldered onto a printed circuit board (PCB) to provide 12 individual RJ45 connections. You state that the connector is intended to make connections to electrical circuits of a voltage not exceeding 1,000 Volts.
In your request, you suggest the subject connector is properly classified as printed circuit connectors under subheading 8536.69.4040, Harmonized Tariff Schedule of the United States (HTSUS). We disagree.
The connector under consideration is comprised of an assembly of multiple RJ45 sockets that are mounted inside a housing. Each individual socket makes connections in electrical circuits for a voltage not exceeding 1,000 volts. However, the subject connector contains multiple sockets that are mounted within a common base. Furthermore, in relying upon HQ 966607 for guidance, a plain reading of heading 8537 refers to two or more apparatus of heading 8536, HTSUS. Based on the facts presented, the subject assembly consists of two or more electrical apparatus (sockets), mounted together on a plastic base, that are used to distribute electrical connections from the individual sockets. As such, heading 8536, HTSUS, is not appropriate.
The applicable subheading for the Stacked RJ45 Connector, Part Number SS73100-046F, will be 8537.10.9170, 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.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8537.10.9170, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8537.10.9170, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the Section 301 trade remedy, you may refer to the relevant parts of the USTR and CBP websites, which are available at:
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions https://www.cbp.gov/trade/remedies/301-certain-products-china
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