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NY N022617

February 28, 2008



TARIFF NO.: 8541.40.8000

Mr. Javier E. Zamora
Hinshaw & Culbertson LLP
222 North LaSalle Street, Suite #300
Chicago, IL 60601

RE: The tariff classification of a safety light curtain from Germany

Dear Mr. Zamora:

In your letter dated January 30, 2008, you requested a tariff classification ruling on behalf of your client, SICK, Inc.

The merchandise subject to this ruling is a safety light curtain. It is identified within the product literature that you submitted as the C4000 Safety Light Curtain. The C4000 safeguards personnel and machines in automated production areas and optimizes work processes. The C4000 system is used vertically, horizontally, or diagonally for safeguarding areas with potential hazards to personnel or equipment. With a flexible design to fit all applications, the C4000 is simple to commission, maintain and utilize.

The safety light curtain uses the through-beam principle which consists of a transmitter and receiver. The transmitter is a light emitting diode (LED) and the receiver is a photo diode. The safety light curtain consists of the following components a sender optic module (a light emitting diode (LED), an LED control circuits, and optical lenses) linked together to form a chain to fit the length of a window assembly, a receiver optical module with photosensitive semiconductor devices (photo diodes with optical lenses and control circuits) matching the length of the sender optic module, and circuitry to extend the optical length by interconnecting additional optic modules (sender and receiver). These components are combined to form a functional unit for emitting (sending) and detecting (receiving) infrared light pulses.

The C4000 will be imported with configuration software, diagnostic software and user manuals on CD-ROM, communications cable for the connection of the sender or receiver to a personal computer allowing configuration and diagnostics of the devices, housings for the sender and receiver components, mounting kits for attaching the housings at customer locations, connecting cables and plugs for interfacing to customer machine controls, interconnecting additional senders and receivers to extend their optical length, mirror columns for redirecting the sender optic modules’ LED infrared output laser diode alignment aid, and test rods to verify operation of the sender receiver optic modules by blocking the infrared beams.

The LED transmitter (sender) and photo diode (receiver) devices of the C4000 safety light curtain are positioned so that the optical emission from the sender is sent to the light sensitive areas of the receiver. The sender converts an electronic input signal to the optical output LED’s that is detected by the receiver photo diodes and converted to electronic output signals, thus allowing the sender and receiver to communicate without any electrical connection between them. When the optical output from the LEDs is interrupted, the electrical output signal in the receiver changes state to indicate the interruption. The electrical output signal in the receiver can be connected to machine controls to shut down machinery in a restricted or safety zone where the safety light curtains are installed.

The applicable subheading for the C4000 Safety Light Curtain will be 8541.40.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Optical coupled isolators.” 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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