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NY I89171




January 16, 2003

CLA-2-84:RR:NC:1:104 I89171

CATEGORY: CLASSIFICATION

TARIFF NO.: 8418.69.0085

Mr. Richard R. Cesati, II
Ferrotec (USA) Corporation
40 Simon Street
Nashua, New Hampshire 03060-3075

RE: The tariff classification of thermoelectric modules from China

Dear Mr. Cesati:

In your letter dated December 18, 2002 you requested a tariff classification ruling.

The thermoelectric modules as imported will consist of a thermoelectric device with integrated heat sinks and a thermistor for temperature feedback, a fan (blower motor with plastic impeller) and a motor driver circuit, all contained in a plastic housing. The housing, which is designed to accept plastic ducting, is roughly circular with a diameter of approximately 5 inches. The modules will be used as part of an automobile’s seat assembly, one for the seat bottom and one for the seat back. The ducting as well as the electronic control package and the seats are added in the United.States.

You indicate that the thermoelectric module is a solid-state refrigeration device used in various heat pumping applications. It operates on the principle of the Peltier effect. When DC voltage is applied to the module, one side becomes cold as heat is pumped to the other side which becomes hot. A reversal of polarity causes this effect to reverse. This provides the basis for a heat pump. It is not a part of or connected in any way to the automobile’s air conditioning system. The application is know as climate controlled seating. It can cool the seat in the summer and warm it in the winter.

The applicable subheading for the thermoelectric module will be 8418.69.0085, Harmonized Tariff Schedule of the United States (HTS), which provides for other refrigerating or freezing equipment: other. The rate of duty will be free.

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 Robert Losche at 646-733-3011.

Sincerely,

Robert B. Swierupski
Director,

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