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HQ 950061

OCTOBER 22 1991

CLA-2:CO:R:C:M 950061 JAS


TARIFF NO.: 8512.90.2000, 8531.90.0000, 8548.00.0000, HTSUSA

David L. Mohn
International Electronic Products
Corporation of America
6-8 North Williams St.
Whitehall, N.Y. 12887

RE: Piezoelectric Buzzer Element; Audio Sound Transducer Element; Electrical Sound Signaling Equipment; Parts

Dear Mr. Mohn:

In your letter of July 15, 1991, you inquire as to the tariff classification of electrical buzzer elements from China. A sample was submitted. Our ruling follows.


The sample buzzer element, designated part AB-27T-4.0A, is a flat ceramic wafer mounted on a brass or stainless steel base. The element measures 1 inch in diameter. Operating on the piezoelectric principal, buzzer elements represented by the sample transduce an electric signal into a mechanical audio signal in the 0.85 to 16.5 kilohertz range. They require no post-importation processing and are simply snapped into a plastic housing in the device with which used. Depending on the electricals of the parent device, these buzzer elements can emit a variety of continuous or intermittent audio signals such as buzzing, chiming, beeping, etc. Literature indicates these elements have a variety of applications, to include automotive warning indicators, burglar alarms and smoke detectors, calculators, door bells, electronic watches and clocks, pagers, timers, and games.


Whether a principal use for these buzzer elements can be established.


Merchandise is classifiable under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA) in accordance with the General Rules of Interpretation (GRIs). GRI 1 states in part that for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes, and provided the headings or notes do not require otherwise, according to GRIs 2 through 6. Additional U.S. Rule of Interpretation 1(c), HTSUSA, states in part that a provision for parts of an article covers products solely or principally used as a part of such article.

Heading 8512 covers electrical apparatus, appliances, and parts thereof specialized for use on bicycles, motorcycles and other motor vehicles for lighting or signaling purposes. The rate of duty is 2.7 percent ad valorem. Horns, sirens and other electrical sound signaling appliances and their parts are among the articles included. Heading 8531 covers electrical apparatus and parts thereof other than those of heading 8512 used for signaling purposes, whether using sound or visual indication for the transmission of the signal. The rate of duty is also 2.7 percent ad valorem. Electric bells, buzzers, chimes, horns, sirens, indicator panels, burglar and fire alarms, and their parts are among the articles included. Classification of the buzzer elements as parts in either of these headings, or in any other heading found to apply, will depend on their principal use. In this case, no evidence of principal use has been submitted.


Buzzer elements for which no principal use can be established will be classifiable as electrical parts of machinery or apparatus, not specified or included elsewhere in [chapter 85], in subheading 8548.00.0000, HTSUSA. This provision covers articles which are identifiable as electrical parts of machinery or apparatus but not as parts of a particular machine or apparatus, and which incorporate a specifically electrical element or elements. The rate of duty under this provision is 3.9 percent ad valorem.


John Durant, Director
Commercial Rulings Division

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