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HQ 084411

August 22, 1989

CLA-2 CO:R:C:G 084411 VEA


TARIFF NO.: 8504.40.0025

Homi Kerawalla, Traffic Manager
International Rectifier Corp.
233 Kansas Street
EL Segundo, California 90245

RE: NYRL 836990 affirmed. solid state device, which has two or more thyristors or rectifier junctions encapsulated in a plastic isolated housing.

Dear Mr. Kerawalla:

Your letter of March 31, 1989, requests reconsideration of a New York ruling dated March 3, 1989 (File 836990), which classified power modules in subheading 8504.40.0025 of the Harmonized Tariff Schedule of the United States Annotated (HTSUSA).


The merchandise consists of a solid state device, which has two or more thyristors or rectifier junctions encapsulated in a plastic isolated housing. The device has the specific function of rectifying alternating current to direct current while controlling large amounts of power.

Our New York office classified the device in subheading 8504.40.0025 as rectifiers and rectifying apparatus. You disagree with this classification claiming that the articles should be classified as diodes in subheading 8541.10.00, or as thyristors, diacs, and triacs, other than photosensitive devices in subheading 8541.30.00. You state that heading 8504 is not the appropriate heading for classifying these articles, because it applies to a complete apparatus that utilizes rectifier components, not to the rectifier or SCR components themselves.


Whether power modules are rectifiers and rectifying apparatus classified in heading 8504, or in heading 8541, HTSUSA.


The General Rules of Interpretation (GRI's), the legal principles by which merchandise is classified, govern classification under the HTSUSA. GRI 1, states in part, that the primary consideration in determining whether merchandise should be classified in a heading should be given to the language of the heading and to any relevant chapter or section notes. The headings at issue in this case, 8504 and 8541 provide:

8504 Electrical transformers, static converters (for example, rectifiers) and inductors: parts thereof:

8504.40.00 Static converters

8541 Diodes, transistors and similar semiconductor devices; photosensitive semiconductor devices, including photovoltaic cells whether or not assembled in modules or made up into panels; light-emitting diodes; mounted piezoelectric crystals; parts thereof:

According to the language of 8504, classification in that heading requires that the article be an electrical transformer; static converter, for example, rectifier or rectifying apparatus; or inductor. The IEEE Standard Dictionary of Electrical and Electronics defines a static converter as a unit that employs static switching devices such as metallic controlled rectifiers, transistors, electronic tubes, or magnetic amplifiers.

The Explanatory Notes for heading 8504 state that the apparatus of this group are used to convert electrical energy in order to adapt it for further use. They may also incorporate various auxiliary devices (e.g. transformer, induction coils, resistors, command regulators, etc.) Their operation is based on the principle that the converting elements act alternatively as conductors and non-conductors.

This group includes rectifiers, by which alternating current (single or polyphase) is converted to direct current, generally accompanied by a voltage change.

The article at issue is a rectifying apparatus and is specifically described in heading 8504. Your submission states that it consists of two or more rectifying junctions encapsulated in a plastic isolated housing, which has the function of rectifying alternating current into direct current at high power. Your argument that these articles cannot be described in heading 8504 because it applies to complete apparatus that utilize rectifier components and not to the rectifier or SCR components themselves, is without merit. The language of heading 8504 states that it applies to static converters. Rectifiers or rectifying apparatus are listed as types of static converters included in this heading.


Power modules are rectifying apparatus classified in heading 8504, subheading 8504.40.0025, HTSUSA.


John Durant, Director

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