CLA-2-85:RR:NC:1:112 D82916
Ms. Fusae Nara
Winthrop, Stimson, Putnam & Roberts
One Battery Park Plaza
New York, NY 10004-1490
RE: The tariff classification of a control panel assembly. The
country of origin is not stated.
Dear Ms. Nara:
In your letter dated September 22, 1998, on behalf of Sharp
Manufacturing Company of America, you requested a tariff
classification ruling.
As indicated by the submitted sample, the control panel
assembly, which is used in a microwave oven, consists of two
printed wiring boards, a liquid crystal display, and a key sheet,
all of which are encased in a plastic housing. The larger of the
two wiring boards is connected to a smaller board by means of a
ribbon connector. The smaller board, in turn, is connected to
the liquid crystal display. When assembled into the microwave,
the user is able to input data for operation of the oven by
pressing one of the options indicated on the key sheet.
The applicable subheading for the control panel assembly
will be 8537.10.3000, Harmonized Tariff Schedule of the United
States (HTS), which provides for boards, panels, ... and other
bases, ..., for electric control or the distribution of
electricity, ...: For a voltage not exceeding 1,000 V: Assembled
with outer housing or supports, for the goods of headings 8421,
8422, 8450 or 8516. The general rate of duty will be 3.2 percent
ad valorem.
In your request you express the opinion that the control
panel assembly should be classified in subheading 8516.90.50,
HTS, which provides for other parts for the microwave ovens of
subheading 8516.50. In particular, you cite HQ 960103 and
HQ 960104 wherein it was held that the presence of a door latch
assembly progressed the assembly so that it was no longer
recognizable as a heading 8537 control panel. Since the control
panel assembly in your request does not contain a door latch
assembly, we do not believe that classification in heading 8537
is precluded.
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 David
Curran at 212-466-5680.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division