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NY R00461

July 1, 2004
CLA-2-85:RR:NC:MM:109 R00461


TARIFF NO.: 8518.90.8000 8534.00.00

Ms. Ian Frank White
Director, IFWtech Limited
52 Abingdon Road (Drayton)
Abingdon, United Kingdom OX14 4HP

RE: The tariff classification of The Triode Board Kit, The Triode Board, The Tetrode Boards Kit, and The Tetrode Boards from an unspecified country

Dear Mr. White:

In your letter received on June 14, 2004, you requested a tariff classification ruling for the four articles listed below and any future products that conform to the same descriptions. However, the merchandise subject to this ruling pertains to Articles 1, 2, 3, and 4 listed below only.

The merchandise is referenced in your letter as Article 1, Article 2, Article 3 and Article 4. Article 1 represents “The Triode Board” Kit, Article 2 represents “The Triode Board”, Article 3 represents “The Tetrode Boards” Kit and Article 4 represents “The Tetrode Boards”.

You describe Article 1 “The Triode Board” Kit as a kit comprising an electronic control circuit. (Although it is primarily intended to be incorporated into a radio transmitter, this article has no radio receiving or transmitting capabilities of its own; it is a control circuit only.) To be more specific, “The Triode Board” Kit will be incorporated into an amplifier, which will be placed into a radio transmitter. The contents of “The Triode Board” kit are 1) a bare circuit board, into which the user will assemble the components, 2) a number of plastic bags containing the components required to populate the board. (These include assorted resistors, capacitors, semiconductors and other hardware; specific details are given in the components list in the instruction manual.), and 3) an instruction manual describing the circuit functions, assembly and commissioning, and a components list.

You describe Article 2 “The Triode Board” as consisting of 1) a bare circuit board and 2) an instruction manual.

You describe Article 3 “The Tetrode Boards” Kit as essentially the same as Article 1 (“The Triode Board” Kit). The contents of “The Tetrode Boards” Kit are two bare circuit boards, components similar to Article 1 (assorted resistors, capacitors, semiconductors and other hardware), and an instructional manual.

You describe Article 4 “The Tetrode Boards” as consisting of 1) two bare circuit boards and 2) an instruction manual.

Your letter suggested HTS 9503.30.0020, which provides for “Other construction sets and constructional toys, and parts and accessories thereof: other.” However, these products are not educational toys. One would need extensive electrical engineer training to understand the instructions. Toys generally do not deal with high-voltage, as these products would. Article 1 “The Triode Board” Kit and Article 3 “The Tetrode Boards” Kit are unassembled printed circuit assemblies for an amplifier, classifiable within subheading 8518.90 as parts of amplifiers. Article 2 “The Triode Board” and Article 4 “The Tetrode Boards” are bare printed circuit boards, classifiable within subheading 8534.00 as printed circuits.

The applicable subheading for “The Triode Board” Kit and “The Tetrode Boards” Kit will be 8518.90.8000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Microphones audio-frequency electric amplifiers; parts thereof: Parts: Other: Other.” The rate of duty will be 4.9 percent ad valorem.

The applicable subheading for “The Triode Board” and “The Tetrode Boards” will be 8534.00.00, Harmonized Tariff Schedule of the United States (HTS), which provides for “Printed circuits.” The rate of duty will be free.

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

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Linda M. Hackett at 646-733-3015.


Robert B. Swierupski

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