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NY N014461

August 7, 2007



TARIFF NO.: 8534.00.0080

Mr. Michael E. Roll
Pisani & Roll
Attorneys at Law
1875 Century Park East, Suite 600
Los Angeles, CA 90067

RE: The tariff classification of flexible substrates from an unspecified country

Dear Mr. Roll:

In your letter dated July 13, 2007 you requested a tariff classification ruling on behalf of your client, Precision Interconnect (“PI”) a division of Tyco Electronics Corporation.

The merchandise subject to this ruling is flexible substrates, single use, 10 lead ECG (electrocardiograph) sets (“FS ECG Sets”). The FS ECG Sets are circuits that are designed to detect the electrical signals generated by the human heart and convey them to an electrocardiograph machine that either displays the electrical signals or traces the signals onto graph paper. Through an ECG test, the electrical activity of the heart, such as the rate and regularity of the heartbeat, as well as the hearts ability to pump blood, can be detected. In addition, damage to the heart muscle can also be shown.

The FS ECG Sets are manufactured by applying a conductive ink along the length of each lead (using a standard screen printing technique) to a flexible polyester substrate material .005 inches - .007 inches thick. The conductive inks are also covered with a protective insulating material that is likewise screen printed. The distal end of the product (closest to the patient) features 10 passive electrodes that are attached to various parts of the body. The leads connect to these electrodes are terminated at the proximal end of the FS ECG Sets to permit connection to an electrocardiograph system. Other than the gel and liners present at the distal end, permitting attachment, i.e. connection, of the electrodes to the body, the FS ECG Sets are not manufactured with any elements other than those obtained during the printing process, which can produce, rectify, modulate, or amplify an electrical signal. Once the liner is removed, the gel side is exposed. The gel side is adhered to the patient. Thus, the only function of the gel is to act as a connector to the patient. As such, the FS ECG Sets are flexible printed circuits that do not contain any elements that can produce, rectify, modulate, or amplify an electrical signal. A sample of this merchandise was submitted for classification and is being returned as per your request.

The applicable subheading for the flexible substrates, single use, 10 lead ECG (electrocardiograph) sets (“FS ECG Sets”) will be 8534.00.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Printed circuits: Other: Flexible type.” The rate of duty will be free.

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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