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NY N022477

February 19, 2008



TARIFF NO.: 8537.10.9060

Ms. Stacy Hallon
Nippon Express USA
1100 N. 28th Ave.
DFW Airport, TX 75261

RE: The tariff classification of a controller from Japan.

Dear Ms. Hallon:

In your letter dated January 22, 2008, you requested a tariff classification ruling on behalf of your client, Daikin AC (Americas), Incorporated.

The merchandise under consideration is the Daikin Intelligent Touch Controller, Model DCS601C71. The Intelligent Touch Controller is a systems controller most suitable for middle and small size buildings for controlling heating, ventilating, air conditioning (HVAC) and lighting systems. This controller consists of a plastic housing measuring approximately 9 inches wide by 6 inches high and 2 inches deep with an extension protruding out the back 2¼ inches to accommodate electrical components, terminal strips and sockets. The unit is designed for mounting flush to a wall with the extension recessed into a junction box for all electrical connections. The face of the controller features an LCD (Liquid Crystal Display) with an analog resistive touch panel measuring approximately 4 inches high by 5 inches wide. Internal memory consists of 4Mbit of SRAM, 128MB of SDRM, EEPROM and flash memory. A touch pen is provided and located in a holder on the top of the housing. On the side of the housing is a PCMCI flash memory card slot for use when updating the controller software to a newer version.

The Intelligent Touch Controller is capable of controlling and monitoring up to 64 groups of units. Up to 128 zones can be set with one Intelligent Touch Controller. Its main functions include starting and stopping of operations of indoor units, temperature settings, switching between temperature control modes, scheduling by zone or group, monitoring of operation status, display of air conditioner operation history, enabling and disabling of operation with an optional hand-held remote control by zone or groups of units, and the option of controlling and monitoring of air conditioners with a personal computer (PC) from a remote location via the Web. The Intelligent Touch Controller automatically controls change over settings switching between cooling and heating according to room temperatures, temperature limit setting which prevents the temperature from rising too high or too low in unmanned rooms and optimizes heating by stopping uncomfortable hot air from blowing when thermostat is off.

The Intelligent Touch Controller operates on 24 Volts AC and provides separate terminal strips for power supply and distribution. Additional sockets are provided for connections to LAN, Ethernet, Internet and telecommunication systems.

The applicable subheading for the Daikin Intelligent Touch Controller, Model DCS601C71 will be 8537.10.9060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Boards, panels, consolesand other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity: For a voltage not exceeding 1,000 V: Other: Other: Programmable controllers.” The general rate of duty will be 2.7 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 Thomas Campanelli at 646-733-3016.


Robert B. Swierupski

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