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HQ 087499


October 9, 1990

CLA-2 CO:R:C:G 087499 CMS

CATEGORY: CLASSIFICATION

TARIFF NO.: 9027.80.40
9027.90.40
9030.39.00
8537.10.00

Doug Lenhart, Ph.D.
Vice President of Marketing
Cypress Systems, Inc.
P.O. Box 3931
Lawrence, Kansas 66046

RE: Potentiostat; Galvanostat; Rotating Ring and Disc Electrode; Tachyprocesseur Speed Control Unit; Instruments For Electrochemical Analysis; Electrochemistry

Dear Dr. Lenhart,

Your request dated June 5, 1990, for a classification ruling on certain electrochemical analysis equipment has been forwarded by the Regional Commissioner of Customs, New York to Customs Headquarters for a reply. Our ruling follows.

FACTS:

The merchandise consists of certain components manufactured by Tacussel Electronique for use in electrochemical analysis. The components are the PJT 24-1 Potentiostat/Galvanostat, PJT 35- 2 AC/DC Potentiostat/Galvanostat, BIPAD Bipotentiostat/ Galvanostat, EAD-10000 Rotating Ring and Disc Electrode (RRDE), and Tachyprocesseur Speed Control Unit for the RRDE. The components may or may not be entered together.

The PJT 24-1 unit is a potentiostat/galvanostat which is used to analyze materials by measuring the chemical response to electrical stimulation. The unit has three jacks for electrodes (not included) which are immersed in a solution in which the materials being analyzed, such as metals or metal salts, are dissolved. The unit provides a continuous measurement of the working electrode potential. The imposed signal is adjustable between +/- 5V or between +/- 10V if coupled with a signal generator (e.g., the Tacussel IMT1, see HQ Ruling 087498).

The PJT 35-2 AC/DC unit is a potentiostat/galvanostat with
two built in adjustable voltage sources and an ohmic drop compensation device. Like the PJT 24-1, the unit uses electrodes (not included) to measure the chemical response to electrical stimulation; the unit's imposed voltage range can also be extended if coupled to a signal generator.

The BIPAD unit is a potentiostat/galvanostat with two potentiostats with independent feedback loops. The unit controls the potentials of two working electrodes versus the same reference electrode. It is mainly designed for rotating ring and disc electrode experiments (e.g., monitoring of intermediate compounds and kinetic investigations). Currents can be read on two analog zero-centre meters. Like the PJT 24-1 the unit measures the chemical response to electrical stimulation.

The EAD-10000 Rotating Ring and Disc Electrode (RRDE) is used with the BIPAD Bipotentiostat/Galvanostat. The electrode is equipped with a servo-controlled and variable speed motor which drives the rotating stem part of the electrode between 100 and 10000 rpm. The standard disc and ring electrode models are made of platinum.

The Tachyprocesseur-Speed Control Unit controls the rotation speed of the RRDE. The rotation speed is displayed on a LCD.

The importer states that the imported components are intended to be used in the study of the corrosion of metals. Other uses include analyzing the charge and purity of materials and the rate of reaction.

ISSUE:

1. Are the PJT 24-1, PJT 35-2, BIPAD and EAD-10000 units classified as instruments and apparatus for physical or chemical analysis in Heading 9027, or as instruments and apparatus for measuring or checking electrical quantities in Heading 9030?

2. Is the Tachyprocesseur unit classified as a control panel or control base in Heading 8537, or as an instrument and apparatus for physical or chemical analysis in Heading 9027?

LAW AND ANALYSIS:

Heading 9030 in pertinent part describes instruments and apparatus for measuring or checking electrical quantities. Heading 9027 in pertinent part provides for instruments and apparatus for physical or chemical analysis. The features of the potentiostat/galvanostats under consideration, including their amperage ranges, make them suitable for testing materials, such as metals and metal salts, by measuring the chemical responses to electrical stimulation. These components are designed to function in a system which performs electrochemical analysis.

They are used in the measuring of electrical quantities, but do this principally to perform physical or chemical analysis. The potentionstat/galvanostats are more specifically described by Heading 9027 and are classified in 9027.80.40, HTSUSA.

Like the potentiostat/galvanostats, the RRDE's are principally used for electrochemical analysis. When entered separately the RRDE's are classified as parts of instruments or apparatus for physical or chemical analysis in 9027.90.40, HTSUSA. When entered with the potentiostat/galvanostats with which they function the RRDE's are classified with those components as functional units in 9027.80.40, HTSUSA.

The Tachyprocesseur units are principally used to control the rotation speed of the RRDE's. When entered separately from the electrodes they control they are classified as control panels or control bases in 8537.10.00. When entered with the electrodes they are classified with the electrodes as functional units in 9027.80.40, HTSUSA.

HOLDING:

The PJT 24-1 Potentiostat/Galvanostat, PJT 35-2 AC/DC Potentiostat/Galvanostat and BIPAD Bipotentiostat/Galvanostat are classified as instruments and apparatus for physical or chemical analysis in 9027.80.40, HTSUSA.

The EAD-10000 Rotating Ring and Disc Electrodes entered separately are classified as parts of instruments and apparatus for physical or chemical analysis in 9027.90.40, HTSUSA. When entered with potentiostat/galvanostats or speed control units with which they function the RRDE's are classified with those components as functional units in 9027.80.40, HTSUSA.

The Tachyprocesseur Speed Control Units entered separately are classified as a control panels or control bases in 8537.10.00, HTSUSA. When entered with the electrodes they control the Units are classified with the electrodes as functional units in 9027.80.40, HTSUSA.

Sincerely,


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