HQ 957324 - Printed Circuit Board (PCB) Assemblies; AC Servo Drives; EN 85.04(II) HQ 954408 - United States International Trade Commision Rulings

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HQ 957324

January 25, 1995

CLA-2 CO:R:C:M 957324 RFA

CATEGORY: CLASSIFICATION

TARIFF NO.: 8504.40.80

Mr. David A. Johnson
Reliance Electric Motion Control
6950 Washington Avenue South
Eden Prairie, MN 55344

RE: Printed Circuit Board (PCB) Assemblies; AC Servo Drives; EN 85.04(II) HQ 954408

Dear Mr. Johnson:

This is in response to your letter dated November 10, 1994, concerning the tariff classification of the printed circuit boards assemblies for AC servo drives under the Harmonized Tariff Schedule of the United States (HTSUS).

FACTS:

The merchandise, labeled as PAMJ printed circuit boards (PCBs), and identified by your assembly part numbers 0042-6731(10 amp), 0042-6732 (20 amp), and 0042-6733 (30 amp), are to be installed into AC servo drives. They will be manufactured in Japan by your affiliate, Reliance Electric Japan (REJ). The function of the PCBs is to convert a single phase 50 or 60 Hz AC input voltage into a DC voltage (rectifier). Then, through pulse width modulation (PWM) techniques, the DC voltage is converted into a variable frequency, variable 3-phase AC voltage for powering a brushless AC motor. The AC input is rectified with full wave power bridge rectifiers. The rectified current charges the bus capacitors to produce a filtered DC voltage. The DC voltage, or DC bus, has 2 primary purposes: first, the logic power supply transforms the high voltage DC bus into lower voltage power for the signal level electronics; secondly, it provides power to a brushless AC motor.

In order to provide the required power to the motor, both the frequency and the current are controlled. The PCB does not control either frequency or current, but it provides the power switches that are controlled by external circuitry. These power devices are connected in a 3-way H-bridge to be able to switch each motor wire either to the positive voltage bus or the negative voltage bus. A control board, installed with the PCB, precisely controls the power to a 3-phase AC motor and thereby controls its motion. The final product which contain these PCBs is used in industrial applications which require precise control of motor position, velocity, or torque. Applications include specialty machines, packaging machines, and machine tools.

ISSUE:

Are the PCBs which are installed into AC servo drives, classifiable as electrical static converters or as parts of electrical static converters under the HTSUS?

LAW AND ANALYSIS:

Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation (GRI's). GRI 1 provides that classification shall be determined according to the terms of the headings and any relative section or chapter notes.

In HQ 954408, dated January 19, 1994, Customs dealt with the classification of AC motor drives which were electrical devices designed to supply AC electricity corresponding to a smooth sinusoidal wave-form at variable voltages and frequencies. The AC motor drive in that case was comprised of a DC supply obtained from a bridge rectifier fed by 3-phase AC input lines, a filter capacitor circuit, an inverter consisting of six power transistors, and a microprocessor. The rectifier converted AC electricity into DC electricity. The DC supply was then filtered in the capacitor circuit and passed through the inverter to produce regulated AC electricity.

In HQ 954408, Customs looked to the Harmonized Commodity Description and Coding System Explanatory Notes (ENs) which constitute the Customs Cooperation Council's official interpretation of the HTSUS. While not legally binding, the ENs provide a commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these headings. See T.D. 89-80, 54 FR 35127, 35128 (August 23, 1989). EN 85.04(II), page 1338, states as follows:

ELECTRICAL STATIC CONVERTERS

The apparatus of this group are used to convert electrical energy in order to adapt it for further use. They incorporate converting elements (e.g., valves) of different types. They may also incorporate various auxiliary devices (e.g., transformers, induction coils, resistors, command regulators, etc.). Their operation is based on the principle that the converting elements act alternately as conductors and non-conductors.

The fact that these apparatus often incorporate auxiliary circuits to regulate the voltage of the emerging current does not affect their classification in this group, nor does the fact that they are sometimes referred to as voltage or current regulators.

This group includes:

(A) Rectifiers by which alternating current (single or polyphase is converted to direct current, generally accompanied by a voltage change.

(B) Inverters by which direct current is converted to alternating current.

Based upon this description in EN 85.04(II), Customs determined that the AC motor drive which included a rectifier and an inverter, was classifiable as a static converter because the purpose of the merchandise was to convert electrical energy in order to adapt it for further use. See HQ 954408.

According to the information provided, the subject PCB assemblies convert a single phase 50 or 60 Hz AC input voltage into a DC voltage (rectifier). Then, through pulse width modulation (PWM) techniques, the DC voltage is converted into a variable frequency, variable 3-phase AC voltage for powering a brushless AC motor. The AC input is rectified with full wave power bridge rectifiers. The rectified current charges the bus capacitors to produce a filtered DC voltage. Based upon this information, Customs finds that the subject merchandise meets the definition of a static converter (inverter) and is provided for under heading 8504, HTSUS. It is classifiable under subheading 8504.40.80, HTSUS, as other static converters.

HOLDING:

The PCB assemblies are classifiable under subheading 8504.40.80, HTSUS, which provides for: "[e]lectrical transformers, static converters (for example, rectifiers) and inductors; parts thereof: [s]tatic converters: [o]ther. . . ." The general, column one rate of duty is 2.7 percent ad valorem.

Sincerely,

John Durant, Director
Commercial Rulings Division

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