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NY L87003





September 13, 2005

CLA-2-85:RR:NC:1:110 L87003

CATEGORY: CLASSIFICATION

TARIFF NO.: 8536.30.8000; 8538.90.3000; 8543.81.0000; 8543.89.4000

Ms. Marilyn Gols
Senator International
1469 Hamilton Pkwy.
Itasca, IL 60143

RE: The tariff classification of electrical components from Germany, Hungary, Indonesia, Italy and Switzerland.

Dear Ms. Gols:

In your letter dated August 17, 2005 on behalf of your client Pepperl & Fuchs, Inc. you requested a tariff classification ruling.

The merchandise under consideration consists of five items, Part Numbers (P/N) Z787, 2700-G, KFA5-SR2-EX2.W, IPC03-50 and IA5-18GM-I3. Samples of all items were submitted with your ruling request and will be returned to you. The Z787, 2700-G and KFA5-SR2-EX2.W are electrical in nature and designed exclusively to be installed into a termination board within an industrial control panel or system (e.g. Programmable Logic Controller (PLC). These products are for use in a processing plant within a hazardous or combustible environment. Part Numbers Z787, 2700-G and KFA5-SR2-EX2.W are printed circuit assemblies within plastic housings for mounting onto a termination board. They measure approximately ” wide by 4” to 4¼” high and are 5” deep.

P/N Z787 is a “Safe Snap Barrier”, or zener diode barrier. The Z787 is an electrical apparatus designed to protect a circuit by limiting the current and voltage. Within the plastic housing is a series of diodes, a resister and a fuse for each line. The diodes limit voltage and the resistor limits the voltage to a field transmitter in a hazardous area eliminating the possibility of a spark that could ignite a surrounding combustible environment. The fuses within the housing will blow if the load is increased beyond a safe operating current or amperes. The fuses are one-time fuses and cannot be replaced within the Z787. The entire unit must be replaced. The Z787 is rated for a maximum voltage of 28V.

P/N 2700-G is a 32 Channel Hart® Multiplexer. This device combines 32 analog signals into one output for connections to “smart” transmitters or control devices supporting digital communication according to the Hart standard. The Hart standard is a communication protocol exclusive to Pepperl & Fuchs. The 2700-G acts as an interface between a Programmable Logic Controller (PLC) or control system and the Hart field devices. Two RS-485 serial port sockets located at the back of the assembly complete all electrical connections. This device has a maximum voltage rating of 30V. In your letter you suggest classification under 8536.30.8000. However, the 2700-G is not performing any of the functions listed under heading of 8536.

P/N KFA5-SR-Ex2.W is a galvanic isolation switch. This device is used to transfer discrete signals from a hazardous area to a safe area. Galvanic isolation is the isolation between an input and output signal, thereby preventing a higher voltage from entering a hazardous area. The KFA5-SR-Ex2.W receives discrete input signals of very low voltage from sensors located within a hazardous or combustible area. The signals are then output to a PLC or control panel at a higher voltage. This device has a maximum voltage rating of 250V, contacts are rated at 2 amps for 250V and 4 amps at 120V. In HQ 952885 and 852101 Customs classified certain input and output modules for industrial control systems in subheading 8538.90.

P/N IPC03-50 is a Inductive Read/Write Data Carrier or fixed code proximity disk measuring approximately 2” in diameter and ” thick. It is an industrial way of bar coding by means of affixing this disk to a product. Within this disk is a coil of wire and a resistor. Used in RFID (Radio Frequency Identification) applications, sensors read the disk as it passes and identifies its precise location. In your letter you suggest classification under 8542.10.0000 as cards incorporating an integrated circuit. However, the IPC03-50 is not an integrated circuit and is not a good of heading 8542.

P/N IA5-18GM-I3 is a Proximity Sensor. This device is an inductive analog sensor cylindrical in shape with a 6’ 3-conductor, #20AWG cord. The IA5-18GM-I3 provides a low voltage linear output signal proportional to the sensing distance from a metal target. It is used in industrial applications were precise positioning is required. The IA5-18GM-I3 has a maximum voltage rating of 30V. In your letter you suggest classification under 8536.50.9065 as a switch. However, the IA5-18GM-I3 does not perform any switching and is more specifically provided for under heading 8543.

The applicable subheading for the Z787 Safe Snap Barrier will be 8536.30.8000, 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 circuitsfor a voltage not exceeding 1,000 V: Other apparatus for protecting electrical circuits: Other.” The general rate of duty will be 2.7 percent ad valorem.

The applicable subheading for the 2700-G 32 Channel Hart® Multiplexer will be 8538.90.3000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Parts suitable for use solely or principally with the apparatus of heading8537: Other: Printed circuit assemblies: Other.” The general rate of duty will be 3.5 percent ad valorem.

The applicable subheading for the KFA5-SR-Ex2.W galvanic isolation switch will be 8538.90.3000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Parts suitable for use solely or principally with the apparatus of heading8537: Other: Printed circuit assemblies: Other.” The general rate of duty will be 3.5 percent ad valorem.

The applicable subheading for the IPC03-50 Inductive Read/Write Data Carrier will be 8543.81.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electrical... apparatus, having individual functions, not specified or included elsewhere...: Other...apparatus: Proximity...tags.” The general rate of duty will be Free.

The applicable subheading for the IA5-18GM-I3 Special Proximity Sensor will be 8543.89.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electrical...apparatus, having individual functions, not specified elsewhere...: Other...apparatus: Other: Electric...transducers.” The general rate of duty will be 2.6%.

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.

Sincerely,

Robert B. Swierupski
Director,

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