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NY 860364

Feb 26, 1991



TARIFF NO.: 8607.19.9000

Ms. Liz Miressi
Hitachi America, Ltd.
50 Prospect Avenue
Tarrytown, NY 10591-4698

RE: The tariff classification of railway equipment from Japan

Dear Ms. Miressi:

In your letter dated February 6, 1991 you requested a tariff classification ruling. You have submitted descriptive literature.

The imported product is an Hitachi VVVF AC Inverter Drive Propulsion System. Your information states that the system consists of two essential parts, the VVVF inverter control equipment and the traction motor. The VVVF inverter control equipment consists of an inverter and a gate controller. The inverter consists of U-phase, V-phase and W-phase, each incorporating a filter capacitor to convert DC current to three- phase AC current. It also contains GTO thyristors which turn the current on and off. A nonsubmerged element type cooing unit is installed for each phase of the inverter. The gate control logic incorporates a unit generating the binary signal of the gate turn off (GTO) thyristor by means of a 16 bit microprocessor.

The traction motor is a 3-phase squirrel cage AC induction motor. It uses a 200c insulation system and includes L-packed type bearings, a gear unit and a gear unit coupling. Your product information states the traction motor as having 170 kW. Depending on the customer's requirements, the motor can range from 135 kW up to 170 kW. The VVVF inverter drive propulsion system is used for railway rolling stock and is recognized as an alternative driving system to the chopper controlled DC traction motor.

It is your opinion the VVVF inverter control equipment is classified in subheading 8504.40.0040, Harmonized Tariff Schedule (HTS), and the traction motor is classified in subheading 8501.53.4080, HTS. The Notes to Section XVI, HTS, (which includes chapter 85) excludes articles of Section XVII, in which the rolling stock provisions fall. Therefore, the imported product cannot be classified in chapter 85.

The applicable subheading for the Hitachi VVVF AC Inverter Drive Propulsion System will be 8607.19.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts of truck assemblies of headings 8605 or 8606 (railway rolling stock). The rate of duty will be 3.9 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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