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NY R00691

August 19, 2004
CLA-2-85:RR:NC:1:110 R00691


TARIFF NO.: 8536.90.4000

Mr. Laurence Storch
Dilworth Paxson LLP
1818 N St. NW, Suite 400
Washington, DC 20036

RE: The tariff classification of coupling from the Czech Republic.

Dear Mr. Storch:

In your letter dated August 11, 2004, on behalf of your client Schott North America, Inc. you requested a tariff classification ruling.

The merchandise under consideration is described as “FT Products.” From the information you provided with your ruling request, there appears to be two items. Both FT Products consist of several parts including a single metal cylinder shaped body with a round glass insulator in the center and one or two gold plated post. Both FT Products are approximately ” in length and ¼” in diameter. One mechanical drawing illustrates Product No. SL 01.475.901 as having one gold plated post in the center of the glass insulator. The mechanical illustration for Product No. SL 01.455.901 reveals two gold plated post, one in the center of the glass insulator and one off center connected to the outer cylinder body. These products are used with other components and are incorporated into initiator assemblies used in automobile airbags. They attach to other components within the initiator assemblies thereby completing an electrical connection. The FT Product are not active components, they simply form an electrical connection between other active electrical components in the form of a coupling.

The definition of a coupling from the Modern Dictionary of Electronics, Rudolf F. Graf, Seventh Edition states:
coupling - The association or mutual relationship of two or more circuits or systems in such a way that power may be transferred from one to another. The FT Products appear to meet the definition of an electrical coupling.

The applicable subheading for FT Product Numbers SL 01.475.901 and SL 01.455.901 will be 8536.90.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuitsnot exceeding 1,000 V: Other apparatus: Terminals, electrical splices and electrical couplings; wafer probers.” The general 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 Eileen S. Kaplan at 646-733-3016.


Robert B. Swierupski

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