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NY J85322




June 11, 2003

CLA-2-73:RR:NC:N1:113 J85322

CATEGORY: CLASSIFICATION

TARIFF NO.: 7326.90.8587; 8544.51.9000; 3926.90.9880

Mr. Karl F. Krueger
Danzas AEI Customs Brokerage Services
29200 Northwestern Highway
Southfield, MI 48034

RE: The tariff classification of components for a steel wireway from Switzerland.

Dear Mr. Krueger:

In your letter dated May 20, 2003, you requested a ruling on behalf of SIG Doboy Inc. on tariff classification.

The samples you provided are components for a steel wireway. The wireway consists of an open topped, galvanized non-alloy steel conduit, stamped from flat-rolled steel, with sides fabricated to accept a lid and hold it in place when it is snapped on. It accepts plastic clips, which restrain wiring below the surface of the wireway. There are also holes regularly spaced along the base of the conduit to allow it to be screwed to a mounting surface. Clips are stamped into the base at regular intervals to allow the conduit to be divided into two sections by a divider. The wireways come in several dimensions, in items LFS60060, LFS 60150 and LFS 60100.

In addition, corner pieces (item R2661) and end caps (item R2603) and plastic clips (items M6291 and M6292) are imported. Grounding cables (item L4181) and grounding clips (item L4180) are also imported. One fitting on the grounding cable fits into the grounding clip.

As imported, each packaged unit will consist of three or four 2000mm-long covers, three or four 2000mm-long base pieces and four plastic clips per base.

Plastic clips, dividers, end and corner pieces, ground wires and wire clips will also be imported separately.

The applicable subheading for the packaged unit, the dividers, the end and corner pieces and the ground clips will be 7326.90.8587, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel, other. The general rate of duty will be 2.9 percent ad valorem.

The applicable subheading for the grounding wire will be 8544.51.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for other electric conductors, for a voltage exceeding 80 V but not exceeding 1,000 V: Fitted with connectors: Other: Other. The rate of duty will be 2.6 percent ad valorem.

The applicable subheading for the plastic clips will be 3926.90.9880, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of plastics, other. The general rate of duty will be 5.3 percent ad valorem.

You express the opinion that the grounding clips are classifiable under subheading 8536.90.4000, HTS, which provides for other apparatus for making connections to or in electrical circuits. In our opinion, the grounding clips do not make a connection and, accordingly, are precluded from classification under that subheading.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R.).

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 James Smyth at 646-733-3018.

Sincerely,

Robert B. Swierupski
Director,

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