CLA-2-90:OT:RR:NC:N1: 105
Jessica Islas-Parker
Global Logistical Connections
1450 American Ln ,Ste 1250 Schaumburg, IL 60173
RE: The tariff classification of voltage transducers from Germany
Dear Ms. Islas-Parker:
In your letter dated March 2, 2023, on behalf of your client, Knick Interface, LLC, you requested a tariff classification ruling.
The four items under consideration are described as voltage transducers, which are devices designed to measure voltage in electrical systems. The voltage transducers perform a measuring function by recognizing the input voltage seen and converting it, proportionately, to a standard output signal across an isolation barrier based on inductive coupling. The transducers measure voltage anywhere from a small mV level, up to 4800 V, both AC and DC. The units of measure provided by the transducers are considered “standard” unit ranges recognized by industrial control systems and are provided to the user by means of output wiring, which contain the electrical output signal. The input voltages are converted to a standardized low-voltage signal. This signal is then converted to a pulse width modulation (PWM) signal. This PWM signal is sent over the isolation barrier to the output through inductive coupling. In the output, the PWM signal is converted to an analog signal proportional to the input voltage. The user then establishes the wiring connection to their data collection or control system of choice. The voltage transducers do not contain a recording device.
The VariTrans P42000 voltage transducer is designed for measuring high voltages up to 3600 V. The device isolates high potentials at the input circuit. The isolating distances are designed to withstand permanent voltages up to 3600 V AC/DC and fast transients up to 20 kV.
The VariTrans P29000 series voltage transducers are available in two input versions for a variety of requirements: high voltage and mV. The devices are designed for monitoring and controlling electrical drive systems operated with DC voltages and feature a passive output for direct connection to a supplying PLC. The device utilizes input voltages from ±100 V to ±1000 V DC. Typical applications are DC current servo drives and generators, as well as power supplies for welding units and inverters for solar or wind power systems.
The VariTrans P41000 voltage transducers are designed for measurements of bipolar voltages from millivolts to volts. They reliably isolate high potentials at the input circuit. The isolating distances are designed to withstand permanent voltages up to 3600 V AC/DC and fast transients up to 20 kV.
The VariTrans P52000 voltage transducer was designed for applications on locomotives and multiple units for short circuit recognition, monitoring and control of traction motors and converters, auxiliary converters, accumulator batteries and others. The device has the flexibility provided by switchable measuring ranges and an integrated broad-range power supply. The P52000 allows for Voltage measurement up to 4800 V with calibrated switching of measuring ranges.
In your letter, you state that the P42000, P29000, P41000 and P52000 voltage transducers operate very similarly to the voltage transducers in NY A86072 (dated August 20, 1996), which was affirmed by headquarters in HQ 960389 (dated March 19, 1998). We agree.
Accordingly, as suggested in your letter, the applicable subheading for the voltage transducers will be 9030.33.3800, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “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 or power (other than those for measuring or checking semiconductor wafers or devices): Other, without a recording device: 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 at https://hts.usitc.gov/current.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Jason Christie at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division