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NY 854572

July 26, 1990

CLA-2-85:S:N:N1:109 854572


TARIFF NO.: 8504.40.0040, 8405.10.0000

William H. Steere
Carrier Corporation
P.O. Box 4808
Carrier Parkway
Syracuse, N.Y. 13221

RE: The tariff classification of fuel cell component parts (inverter and gas generator) from Japan.

Dear Mr. Steere:

In your letter dated June 12, 1990, you requested a tariff classification ruling.

The articles which are parts of the PC25 fuel cell are described as follows:

1. The Electrical System Assembly module which contains all of the electrical equipment plus, some equipment associated with the DC System; specifically a. some items of the Cabinet Ventilation System (CVS) which provides purge and ventilation air to power plant equipment, b. some items of the air processing system which supplies process air to the DC System, and c. some elements of the Water treatment System (Resin Bottles). The principal function of this module appears to be the conversion of direct current (DC) to alternating current (AC).

2. The reformer is the unit that converts natural gas and steam into a gas that is mostly Hydrogen. The gas is then fed to the fuel cell which generates the DC for inversion to AC.

The applicable subheading for the DC module will be 8504.40.0040, Harmonized Tariff Schedule of the United States (HTS), which provides for "Static converters." The rate of duty will be 3 percent ad valorem.

The applicable HTS subheading for the reformer will be 8405.10.0000, which provides for "Producer gas or water gas generators." The rate of duty will be 2.8 percent ad valorem.

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

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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