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NY N005851

February 2, 2007



TARIFF NO.: 8504.40.4000

Ms. Laura Roberts
Customs Compliance Manager
Otis Elevator Company
1331 S. Curry Pike
Bloomington, IN 47403

RE: The tariff classification of an Otis variable frequency (OVF) drive from China

Dear Ms. Roberts:

In your letter dated January 23, 2007 you requested a tariff classification ruling.

The merchandise subject to this ruling is an Otis variable frequency (OVF) drive. The OVF drives are described in your letter as insulated gated bi-polar transistor (IGBT)-Inverters with digital and analog control and are made up of active/passive power electronic devices, a high-speed central controlling unit (microprocessor) and optional sensing devices, depending upon the application requirement. The OVF drive is applicable for low, medium, and high speed geared or gearless elevators with AC motors.

The basic function of the OVF drive is to act as a variable frequency generator in order to vary speed of the elevator motor as per the user setting. The rectifier and the filter convert the alternating current (AC) input to direct current (DC) with negligible ripple. The inverter, under the control of the microcontroller, synthesizes the DC into 3-phase variable voltage, variable frequency AC. Additional features can be provided, such as DC bus voltage sensing, OV and UV trip, over-current protection, accurate speed/position control, temperature control, easy control setting, display, PC connectivity for real time monitoring, etc.

The OVF drive provides open loop speed control for one/two speed elevator motors. The system controls the fast speed of the motor winding during the whole run without using an additional encoder and assures smooth riding comfort, as well as high leveling accuracy under all load conditions. The motor speed is determined by variable frequency output of the OVF drive power section. The 3-phase mains supply is rectified, smoothened by a condenser in the DC link, and the transistor inverter transforms the DC voltage with pulse width modulation into three phase variable voltage and variable frequency output. The digital control generates ideal speed pattern for a predetermined profile with fixed parameters for jerk and acceleration. Load current feedback and speed measurement at the end of each run maintains load independent accurate leveling.

The applicable subheading for the Otis variable frequency (OVF) drive will be 8504.40.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Electrical transformers, static converters (for example, rectifiers) and inductors; parts thereof: Static converters: Speed drive controllers for electric motors.” The rate of duty will be 1.5 percent ad valorem.

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 Linda M. Hackett at 646-733-3015.


Robert B. Swierupski

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