CLA-2-94:RR:NC:2:227 G85230

Mr. Ernesto Bustamante
William F. Joffroy, Inc.
Customs Brokers
P.O. Box 698
Nogales, AZ 85628-0698

RE: The tariff classification of various lamp parts.

Dear Mr. Bustamante:

In your letter dated December 6, 2000, on behalf of ICT, you requested a tariff classification ruling.

The samples submitted consist of the following lamp parts that will be imported into Mexico for assembly purposes:

a metal housing of aluminum, measuring approximately 9 ¾ inches in height by 13 inches in width by 7 ¾ inches in depth, with a borosilicate glass refractor as well as an interior socket and polycarbonate reflector. wire nuts, screws, washers and ballast.

a 175 Watt Sylvania metal halide lamp, lamp type M57.

a capacitor with insulated wire.

You state that the wire nuts are properly classified under heading 3926, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of plastic. However, since these items are more specifically provided for as electrical insulators, consideration of classification under heading 3926, HTS, is precluded.

The applicable subheading for the metal housing will be 9405.99.40, HTS, which provides for lamps and lighting fittings…parts thereof not elsewhere specified or included: other.

The applicable subheading for the wire nuts will be 8546.90.00, HTS, which provides for electrical insulators of any material: other.

The applicable subheading for the screws will be 7318.15.40, HTS, which provides for screws, bolts, nuts…of iron or steel: other screws or bolts, whether or not with their nuts or washers: machine screws 9.5 mm or more in length and 3.2 mm or more in diameter (not including cap screws).

The applicable subheading for the washers will be 7318.21.00, HTS, which provides for screws, bolts, nuts…washers…of iron or steel: non-threaded articles: spring washers and other lock washers.

The appropriate subheading for the ballast will be 8504.10.00, HTS, which provides for electrical transformers, static converters (for example rectifiers) and inductors; parts thereof: ballasts for discharge lamps and tubes.

The appropriate subheading for the metal halide lamp will be 8539.32.00, HTS, which provides for electrical filament or discharge lamps…discharge lamps, other than ultraviolet lamps: mercury or sodium vapor lamps; metal halide lamps. Your inquiry does not provide enough information for us to give a classification ruling on the capacitor with insulated wire. In your letter you request the classification of insulated wire. However, you submitted a sample of a capacitor (identification number 7C100M40R) with insulated wire protruding from one side. Please respond to the following in regard to the insulated wire:

Are you requesting the classification of the insulated wire alone or as submitted, along with the capacitor? Does the capacitor have anything to do with any other items contained within your classification request?

Please submit a sample of the insulated wire of which the classification is being requested.

Further, your letter requests the classification of a ballast and a lamp ignitor. You also state that the ballasts and the starters sent to Mexico are provided for by name in heading 8504, HTS. Based on the above, please respond to the following: What is a lamp ignitor? Is it part of another device? Please furnish a sample of the lamp ignitor only. What is a starter? Is it part of another device? Please furnish a sample of the starter by itself.

When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

If you have any questions regarding the ruling, contact National Import Specialist George Kalkines at 212-637-7073.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division