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HQ 089016


July 2, 1991

CLA-2 CO:R:C:M 089016 AJS

CATEGORY: CLASSIFICATION

TARIFF NO.: 8504.

Mr. Henry M. Haney
806 Eagle Ridge Dr.
Birmingham, AL 35242

RE: Electrical power connectors; high voltage oil-filled instrument transformers; Heading 8504; Liquid dielectric transformer; Subheading 8504.21.00; Subheading 8504.22.00; Subheading 8504.23.00.

Dear Mr. Haney:

This is in reply to your letter of March 11, 1991, requesting a tariff classification ruling under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA).

FACTS:

The articles at issue are electrical power connectors from Mexico or India and instrument transformers from Spain. The transformers are described as high voltage oil-filled instrument transformers. The connectors are not adequately described in the request. We require a more detailed description explaining exactly what the connectors are, where and how they are used, and exactly how they operate. We were unable to locate your phone number, which is unlisted, and the Square D Company was unable to identify the subject connectors when contacted. Until further information is provided, we are unable to offer advice on this portion of your request.

ISSUE:

What is the proper tariff classification of the subject transformers.

LAW AND ANALYSIS:

Heading 8504, HTSUSA, provides for electrical transformers. The subject transformers satisfy this description. They are described as high voltage oil-filled instrument transformers. Oil-filled transformers are a type of liquid dielectric transformer (LDT). Subheading 8504.21.00, HTSUSA, provides for LDTs having a power handling capacity not exceeding 650 kVA. Subheading 8504.22.00, HTSUSA, provides for LDTs having a power handling capacity exceeding 650 kVA but not exceeding 10,000 kVA. Subheading 8504.23.00, HTSUSA, provides for LDTs having a power handling capacity exceeding 10,000 kVA. The kVA measurement of the subject transformers is not specified. Therefore, the proper subheading for the subject transformers cannot be determined at this time.

HOLDING:

The subject transformers are properly classifiable in the appropriate above mentioned subheading, depending on their kVA measurement. Each of these subheadings provide for a duty rate of 2.4 percent ad valorem when products of Spain.

Sincerely,

John Durant, Director
Commercial Rulings Division

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