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NY M87398

November 6, 2006

CLA-2-85:RR:NC:1:110 M87398


TARIFF NO.: 8536.50.9055

Sylvia Perreria
Eagle Global Logistics
8830 NE Alderwood Road
Portland, OR 97220

RE: The tariff classification of limit switches from China.

Dear Ms. Perreria:

In your letter dated October 12, 2006, you requested a tariff classification ruling on behalf of your client, Bray International Inc.

Under consideration are two model numbers of the Series 50 Valve Status Monitor (S50) product line, the Series 50-0400 and the Series S50-0700.

Both styles of S50 merchandise are encased in a die-cast aluminum housing, and consist of a junction box and limit switches. The internal components include adjustable cams, micro switches, a terminal block and a shaft with upper and lower bearings. They also include a visual valve position indicator, but do not themselves incorporate valves. Both styles are waterproof; additionally, the S50-0700 is explosion-proof. Neither is rated for more than 250 volts.

The primary function of the S50 series models is to provide a visual and electrical indication of the operating position of a valve. They display the valve position as either open or closed, and, through internal switches, may also indicate the valve position to a remote location. Although they contain electrical components, the S50s are mechanical limit switches, not electromechanical.

The S50 models are used on butterfly valves and ball valves, and may be used on both hand-operated and automated valves. When installed, the S50s shaft is mechanically linked to the valve’s shaft. The cams mounted on the shaft inside the S50s trip micro switches when the shaft is rotated to either limit (valve-open or valve-closed) of the valve stroke. When either switch is activated, it completes an electrical circuit, thus performing an action based on the mechanical movement of the valve. These actions can include illuminating an indicator light, operating an audible signal, turning on a pump, or any other action an operator may wish to perform based on the valve position.

In your ruling request you suggest a classification of 8481.90.9080, a component part of a valve of heading 8481, for this merchandise. However, in order for an item to be classified as a “part” of an article, that item must be necessary to the completion of the article, and the article must be unable to function without that part. In this case, the S50 series model limit switches are not integral to the function of the valves; rather, they are subsidiary to the valve. They merely indicate the position of the valve, and may perform additional electrical functions based on that information.

The applicable subheading for the Series 50-0400 and 50-0700 limit switches will be 8536.50.9055, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: “Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits (for example, switches, relays, fuses, surge suppressors, plus, sockets, lamp-holders, junction boxes) for a voltage not exceeding 1000 V: Other switches: Other: Other: Limit”. The general rate of duty will be 2.7% ad velorum.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Thomas Campanelli at 646-733-3016.


Robert B. Swierupski

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