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HQ 954060

JULY 26 1993

CLA-2:CO:R:C:M 954060 JAS


TARIFF NO.: 8544.51.80

Ms. Pamela J. Gruszczynski
Midwest Transatlantic Lines, Inc.
1230 West Bagley Road
Berea, Ohio 44017-2910

RE: Electric Cord With Plug; Vacuum Cleaner Cord; Parts of Vacuum Cleaners, Heading 8509; Insulated Conductor, Insulated Electric Conductor; Section XVI, Note 2

Dear Ms. Gruszczynski:

In a letter dated April 22, 1993, on behalf of Royal Appliance Manufacturing, you inquire as to the tariff classification of electric cords for vacuum cleaners, from unspecified countries. A sample and brochure were submitted.


The article in issue is an electrical cord used with a hand- held vacuum cleaner. The cord has hard rubber insulation with a plug on one end and a plastic fitting with two protruding insulated wires at the other end.

Because the electric cord appears to be used principally, if not solely with hand-held vacuum cleaners, you feel it is classifiable in subheading 8509.90.20, Harmonized Tariff Schedule of the United States (HTSUS), a provision for parts of vacuum cleaners. You state that Customs officers in Cleveland have tentatively advised you that the cords are more appropriately classified under a provision for electric conductors.

The provisions under consideration are as follows:

8509.90.20 Electromechanical domestic appliances, with self-contained electric motor; parts thereof: Parts: Parts of vacuum cleaners...3.4 percent - 2 -

8544.51.80 Other electric conductors, for a voltage exceeding 80 V but not exceeding 1,000 V: Fitted with connectors: Other...5.3 percent


Whether electric cords for vacuum cleaners are goods of heading 8544.


Merchandise is classifiable under the Harmonized Tariff Schedule of the United States (HTSUS) 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.

With certain exceptions not relevant here, Section XVI, Note 2(a), HTSUS, states that parts which are goods included in any of the headings of chapters 84 and 85 (other than headings 8485 and 8548) are in all cases to be classified in their respective headings. Section XVI, Note 2(b) states, among other things, that other parts, if suitable for use solely or principally with a particular kind of machine, or with a number of machines of the same heading (including a machine of heading 8479 or 8543) are to be classified with the machines of that kind.

We do not dispute that the electrical cords in issue are integral, constituent or component parts of vacuum cleaners without which the machines could not perform their intended function. Nonetheless, the cords in issue are specially provided for in heading 8544. This heading covers electric wire, cable and other conductors that are insulated and are used as conductors in electrical machinery and apparatus. Wire and cable remain in heading 8544 even if cut to length or fitted with connectors such as plugs, sockets, lugs, jacks, etc. on one end or both.


Under the authority of GRI 1, the electrical cords in issue are provided for in heading 8544. They are classifiable in subheading 8544.51.80, HTSUS, as other electric conductors, - 3 -
fitted with connectors, for a voltage exceeding 80 V but not exceeding 1,000 V. The rate of duty is 5.3 percent ad valorem.


John Durant, Director

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