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HQ 088226


February 26, 1991

CLA-2 CO:R:C:M 088226 CMS

CATEGORY: CLASSIFICATION

TARIFF NO.: 8503.00.40
8504.90.00

Mr. Hector Casas
Casas International Brokerage, Inc.
6775 Customhouse Plaza
Ste. J Otay Mesa
San Ysidro, CA 92073

RE: Voice Coil For Voice Coil Motors; Parts Of Computer Disk Drives; Inductors; Self Induction; Impedance; AC; DC

Dear Mr. Casas,

Your request dated October 3, 1990, on behalf of Systems Magnetic Company, for a classification ruling on certain voice coils has been referred by the Regional Commissioner of Customs, New York to Customs Headquarters for a reply.

FACTS:

The merchandise consists of coils which are used in voice coil motors. The motors in which the coils are used are installed in computer hard disk drive units.

The coils are inserted in a moveable manner within the magnetic field of the voice coil motors. As the coil is moved through the magnetic field a current is induced throughout the coil. A signal is provided to a servo system which calculates the position of the coil and then calculates the desired position for the coil. This enables the positioning of a structure, such as a carriage, on the media.

The circuit in which the coils operate is a DC circuit. The coils do not impede the flow of current and do not utilize self induction in their operation. The coils do not perform the operations of electrical chokes.

ISSUE:

Is the merchandise classified in Heading 8504 as inductors, or in Heading 8503 as parts of the electric motors of Heading 8501?

LAW AND ANALYSIS:

Heading 8504 in pertinent part describes inductors. The Explanatory Notes to Heading 8504, p. 1339, describe inductors as follows:

These consist essentially of a single coil of wire which, inserted in an AC circuit, limits or prevents by its self-induction the flow of the AC. They vary from small chokes used in wireless circuits, instruments, etc., to large coils often mounted in concrete, used in power circuits (e.g., for limiting the flow of current in the event of a short circuit).

Although the articles under consideration are coils, they are not the type of coils which are properly classified as inductors in Heading 8504. The coils do not utilize self- induction in their operation and do not operate in an AC circuit.

The Explanatory Notes to Heading 8504 provide that chokes are types of coils which are classified as inductors in Heading 8504. Van Nostrand's Scientific Encyclopedia, 7th Ed. (1989), p. 620, provides:

CHOKE COIL. This term is applied to various types of inductances used in electrical circuits primarily to present high reactance at certain frequencies. Such coils usually have high reactance compared to their resistance and offer impedance to the flow of alternating currents by the induced counter electromotive force... [Choke coils are often] used in electrical power circuits to block high frequency transients produced by lightning surges.

The voice coils under consideration do not impede the flow of current and do not perform the operations of electrical chokes. The voice coils are also not similar to inductors which might not be chokes but do limit or prevent by self-induction the flow of current in an AC circuit.

Although the motors in which the coils are used are installed in computer hard disk drive units, the particular goods of which the coils are parts are the voice coil motors, not the disk drive units. The coils are suitable for use principally with the electric voice coil motors of Heading 8501. The coils are classified as parts of the electric motors of Heading 8501, in 8503.00.40, HTSUSA.

HOLDING:

The voice coils are classified as parts of the electric motors of Heading 8501, in 8503.00.40, HTSUSA.

Sincerely,


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