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FILE: CLA-1-S:N:N1: 112 811069

TO: Director, Commercial Rulings Division

FROM: Chief, Branch 1
National Import Specialist Staff

SUBJECT: Tariff Classification of a Wirenut

This office received a ruling request from Morris Friedman & Company, on behalf of PM Fasteners, Inc., on the classification of a wirenut from Taiwan. As can be seen from the samples which accompanied the request, this item consists of a cone shaped plastic article into which a small springlike piece of metal has been inserted. Such items are used in electrical applications to join two or more wires. The electrical wires are usually twisted together by hand, and the wirenut is placed over the joined wires and turned. Aside from ensuring a tight connection between the wires, the wirenut also acts as an insulator against the electric current.

In our attempt to respond directly to this ruling, we sought guidance from any prior decisions which may have been issued on this item. Our efforts focused on three possible classifications: heading 8536, as electrical apparatus for making connections; heading 8546, as electrical insulators of any material; and heading 8547, as insulating fittings for electrical machines, appliances or equipment. We were unable to locate any rulings which covered a wirenut, or any item whose function was similar.

A review of the Explanatory Notes for each of these subheadings leads us to believe that heading 8536 would not be applicable based on the examples provided in the EN's. The apparatus for making connections in heading 8536 appears to be intended to cover items whose principal purpose is to complete an electrical circuit. The examples cited include items such as spade terminals and crocodile clips. The wirenut in question only assists in the connection between electrical wires since, as noted above, the wires must be joined together before the wirenut can be used. Likewise, we do not believe that heading 8547 applies because the insulating fittings covered therein are for electrical machines, appliances or equipment, as the examples given in the EN's clearly indicate.

In the opinion of this office, heading 8546, covering electrical insulators of any material, is most applicable to the wirenut. The Explanatory Notes for this subheading state, "Insulators of this heading are used for the fixing, supporting or guiding of electric current conductors while at the same time insulating them electrically from each other, from earth, etc." The wirenut clearly
serves to fix or support the wires by ensuring the connection remains complete, and it also serves as an insulator so that the joined wires do not touch other wires, metal, etc. We believe that the proper classification for the wirenut is under subheading 8546.90.0000, which provides for other electrical insulators of any material.

Should you have any questions on this matter, please contact National Import Specialist David Curran on (212) 466-5680.

Robert Slomovitz

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