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NY L82094




February 15, 2005

CLA-2-85:RR:NC:MM:109 L82094

CATEGORY: CLASSIFICATION

TARIFF NO.: 8533.40.80

Ms. Gail T. Cumins
Sharrets, Paley, Carter & Blauvelt, P.C.
75 Broad Street
New York, NY 10004

RE: The tariff classification of focus pack from an unspecified country

Dear Ms. Cumins:

In your letter dated January 31, 2005 you requested a tariff classification ruling on behalf of Sanyo Electronic Device (USA) Corp. (“SDC”).

The merchandise subject to this ruling is a referenced in your letter as a focus pack. A sample was submitted to this office for classification purposes and is being returned to you as requested.

The focus pack is a piece of electrical apparatus used in a projection television receiver incorporating three cathode-ray tubes (blue, green, and red). It serves to provide, from one incoming source of high voltage, adjustable voltage levels to control the focus and brightness for each of the cathode-ray tubes in the receiver. This is achieved through the use of variable resistors, which modify the amount of resistance in the circuit according to the manner that the six knobs on the face of the device are positioned. The variable resistors are not wirewound.

The focus pack consists of variable resistors, wires, connectors, knobs, and a housing. It is in the shape of a rectangular block measuring approximately 3 inches by 2½ inches by 15/16 inch, to which nine wires are connected in the back. Five of the nine wires are fitted with connectors at their lose ends. There are six rotating knobs, with slots to accommodate a Phillips head screwdriver, on the front of the article arranged in two rows of three. The top row of knobs adjusts the focus, and the bottom (designated “screen” knobs) changes the brightness. Each knob is labeled “B”, “G”, or “R” (blue, green, or red) to indicate the cathode-ray tube in the in the television receiver to which the knob relates. Six of the wires in the back of the article are connected to terminals that correspond to the knobs on the front. These wires are to transmit the modified voltages generated by the focus pack. There is also a pale red wire connected to a terminal on the back near the top of the device (labeled “IN” on the front of the unit), through which incoming voltage is transmitted to the focus pack. In addition, there are two wires (one bright red and one black) connected to two terminals (labeled “DF” and “E” on the front) directly below the terminal for the incoming voltage. Those two wires are fitted at their lose ends to the same three-hole gray connector. The black wire (“E” terminal) connects to a ground on a printed circuit board, while the red cable (“DF” terminal) connects to the dynamic focus on the printed circuit board. The wires, connectors, knobs, and housing contribute to the functioning of the variable resistors and do not have any other independent function(s). As such, the non-wirewound variable resistors impart the essential character of the focus pack.

The applicable subheading for the focus pack will be 8533.40.80, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electrical resistors other than heating resistors; parts thereof: Other variable resistors, including rheostats and potentiometers: 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 Linda M. Hackett at 646-733-3015.

Sincerely,

Robert B. Swierupski
Director,

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