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NY R00509

July 29, 2004
CLA-2-90:RR:NC:N1:105 R00509


TARIFF NO.: 9027.80.8030

Mr. Kerry J. Kiggins
Mettler Toledo, Inc.
60 Collegeview Road
Westerville, OH 43081

RE: The tariff classification of Karl Fischer Titrators from Switzerland

Dear Mr. Kiggins:

In your letter dated July 2, 2004, you requested a tariff classification ruling. No samples were submitted, but you did submit the multiple page Mettler Toledo brochure for the DL53, 55, 58, 70ES and 77 titration systems. You indicate that the systems cost between 5 and 11 thousand US dollars.

You state: “Titrators are used to measure a variety of things. Examples are salt content, acidity, copper in a plating bath. Each titrator has a burette that is mechanically driven with a piston by a burette dive. The burette contains a chemical that reacts with the analyte in question (salt, copper, etc.), which is placed as a sample in a plastic beaker. A reaction occurs between the chemical in the burette and the analyte as the chemical is pushed out of the burette by the burette drive. The completion of this reaction is sensed by an electrode. The burette drive is split into 5000 to 10000 increments. The titrator knows how many increments it took to completd the reaction, and the concentration of the analyte in question can then be calculated.”

Per the brochure, a typical end point for the titration in these devices is when the gradual addition of HCl makes the sample pH 7, i.e., neutral in terms of hydrogen ion concentration.

Electronic titration instruments are Harmonized System Explanatory Note Example 25 to 90.27.

You propose classification in HTS 9027.80.4530. However, it is not “electrical” per Additional US Note 2 to Chapter 90 in that the measurement is made primarily by keeping track of how much reagent was added to the sample before the point at which a certain electrical state was reached so there is no electrical signal whose strength is directly proportional to the level of the substance in the mixture.

The applicable subheading for your five items will be 9027.80.8030, Harmonized Tariff Schedule of the United States (HTS), which provides for “other” chemical analysis instruments and apparatus, not “electrical,” and not using optical radiations. 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 J. Sheridan at 646-733-3012.


Robert B. Swierupski

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