CLA-2-84:RR:NC:1:110 R00689
Mr. Russ Ledbetter
Goodrich Corporation
4115 Corporate Center Drive
Monroe, NC 28110
RE: The tariff classification of various aircraft parts and components from the United Kingdom and France.
Dear Mr. Ledbetter:
In your letter dated August 11, 2004 you requested a tariff classification ruling.
The merchandise under consideration consists of three aircraft components. The first component is the Generator Control Unit (GCU) Part Number 51525-001B. This component appears to be a microprocessor based voltage regulator. The GCU is housed within an aluminum enclosure, which provides secure mounting and an adequate heat sink its internal components. The electronic circuitry is contained on a chassis/motherboard assembly and two printed wiring boards (PWB). From the literature you provided, this component contains the voltage regulation, control, and logic for coordinated system performance during normal and abnormal system operating conditions. The GCU is designed to operate with all TRW Aeronautical Systems. The control functions mentioned in you literature indicate (1) Voltage Regulator, (2) Field Transistor/Short Circuit Protection, (3) Parallel Operation, (4) Current Limiting, (5) Contactor Control, (6) Short Circuit Protection, (7) Start Control and Protection, (8) Field Weakening, (9) Open Shunt Protection, (10) Ling Contactor Control and Protection, and (11) Backup Power.
The second item is the Trimmable Horizontal Stabilizer Actuator (THSA) Part Number 47145-010. This is an actuator used to achieve the longitudinal pitch trim control of an aircraft. The THSA mechanically controls horizontal stabilizer deflection by means of a servosystem whose input signal is an electrical position order transmitted by an onboard computer.
The third item is the Synchro-Shaft Lock, Part Number TY2080-20. This unit’s function is to hold the synchronizing shafts to prevent unwanted operation of the thrust reverser ballscrews. The primary components of this unit are a solenoid, a rotor and switch housing and insert assembly. When the solenoid is not energized the unit is in lock mode. Thus the Thrust Reverser synchronizing shafts on the aircraft are held and the system cannot operate.
The applicable subheading for the Trimmable Horizontal Stabilizer Actuator (THSA) Part Number 47145-010 will be 8412.80.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Other engines and motors, and parts thereof: Other engines and motors: Other.” The general rate of duty will be free.
The applicable subheading for the Synchro-Shaft Lock (Part No. TY2080-20 will be 8505.20.000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electromagnets…electromagnetic or permanent magnet chucks, clamps and similar holding devices; electromagnetic couplings, clutches and brakes; electromagnetic lifting heads; parts thereof: Electromagnetic couplings, clutches and brakes.” The general rate of duty will be 3.1 percent ad valorem.
Regarding classification of the Generator Control Unit (GCU) Part Number 51525-001B, we are returning your request for this item because we need additional information. Please submit the following:
A wiring diagram for each printed circuit board with all components labeled, and a description of what their function is.
Are there any switches, fuses, motor starters, plugs, sockets, lamp-holders or other connectors, terminals, electrical couplings, etc?
Although this component appears to be a microprocessor based voltage regulator, please explain how it performs each of the control functions listed from (2) - (11) above.
Does this component act as a cutout used with generators? If not, does it contain a cutout?
What is the main function of the GCU?
What system operating conditions does it control if any? How does it perform this function?
If you decide to resubmit your request, please include all of the material that we have returned to you and mail your request to U.S. Customs and Border Protection, Customs Information Exchange, 10th Floor, One Penn Plaza, New York, NY 10119, attn: Binding Rulings Section. If your request was submitted electronically and the information required does not involve sending a sample, you can re-submit your request and the additional information electronically.
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 Eileen S. Kaplan at 646-733-3016.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division