CLA-2-85:RR:NC:MM:101 C89835
Mr. Robert Resetar
Customs Manager
Porsche Cars North America, Inc.
980 Hammond Drive
Suite 1000
Atlanta, Georgia 30328
RE: The tariff classification of an Automotive Ignition Control Unit
(Capacitative Discharge System)from Germany
Dear Mr. Resetar:
In your letter dated June 29, 1998 you requested a tariff classification
ruling.
The item is a capacitative discharge ignition control unit also known as a
CDS Unit.
This unit is an alternative to the conventional induction coil system. The
electronic components of the system are contained in the CDS unit.
The light alloy housing of the CDS unit is provided with cooling fins to
help dissipate heat generated by the system. An ignition voltage transformer
takes the place of the conventional induction coil. The transformer is similar
in construction to a coil yet differs considerably. For example; resistance,
voltage gain ration and inductivity match the specific electrical
characteristics of the CDS unit.
When the ignition is turned on, the DC converter steps up the battery
voltage from 12 volts to 450 volts, charging the storage capacitor. This
charging is brought about through periodic impulses at a frequency of
approximately 3,00 Hz; this produces a high a pitch whistling sound in the DC
converter. When the breaker points open, the ignition trigger unit releases an
impulse to the thyristor base. The thyristor becomes conductive. The charge in
the storage capacitor then discharges through the thyristor and ignition voltage
transformer. This causes a high voltage surge on the secondary side which is
carried through the distributor to the spark plug. In the CDS, ignition voltage
rise at the spark plug occurs much faster than in the induction coil ignition.
The applicable subheading for the CDS unit will be 8511.80.6000, Harmonized
Tariff Schedule of the United States (HTS), which provides for Electrical
ignition or starting equipment of a kind used for spark-ignition or compression-
ignition internal combustion engines (for example, ignition magnetos,
magneto-dynamos, ignition coils, spark plugs and glow plugs, starter motors);
generators (for example, dynamos, alternators) and cut-outs of a kind used in
conjunction with such engines; parts thereof:...Other equipment...other. The
rate of duty will be 2.6 percent ad valorem.
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 Robert DeSoucey at 212-466-5667.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division