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NY N018481





October 30, 2007

CLA-2-85:OT:RR:NC:1:110

CATEGORY: CLASSIFICATION

TARIFF NO.: 8536.90.8085; 8534.00.00

Mr. John Wood
Moog Components Group Inc.
1213 North Main Street
Blacksburg, VA 24060-3127

RE: The tariff classification of slip ring components from Costa Rica, the Dominican Republic and Mexico.

Dear Mr. Wood:

In your letter dated October 10, 2007 you requested a tariff classification ruling.

The merchandise under consideration are four slip ring components. Samples of the four components were submitted with your ruling request. The four components are identified as Part Number (P/N) 6023242, Slip Ring Assembly; P/N 4994020000, Brush Block Assembly; P/N 4990004000, Brush Block Assembly; and P/N 6455149000, Printed Circuit Brush Block Assembly.

Slip rings are electromechanical devices that allow the transmission of electricity from a stationary to a rotating structure. A slip ring can be used in any electromechanical system that requires un-restricted, continuous rotation while maintaining contact for transmitting power and/or data. The Slip Ring Assembly P/N 6023242 is a slip ring rotor or capsule. This device is a small insulated shaft measuring approximately 2 inches long with 24 metal contact rings equally spaced on the perimeter of the shaft throughout its length. Each ring is individually connected to a single insulated wire conductor within the shaft. The wire leads extend out from one end of the slip ring rotor for connecting purposes. The Slip Ring Assembly serves as the central shaft suspended on ball bearings or bushings within a device with an equal number of contact points that rotate around it. This device is a single unit that makes a passive electrical connection within a slip ring assembly.

The Brush Block Assembly, P/N 4994020000 is a square molded unit of insulating plastic measuring approximately 2½ inches by 2½ inches and is ¼ inch thick with four mounting holes. This device features 53 pairs of spring-like wire contacts or brushes, each pair connected to an insulated conductor lead for connecting purposes. The wire contacts provide continuous pressure onto the contact rings of a slip ring rotor maintaining a passive electrical connection.

The Brush Block Assembly, P/N 4990004000 is a device designed to be installed within a support structure which contains the rotor bearings or bushings. This device is a plastic molded unit resembling one half of a small cylinder split lengthwise and measures approximately 1 inch long with a diameter of of an inch. It is designed to rotate around a slip ring rotor. This device is a single unit that features 7 pairs of spring-like wire contacts or brushes; each pair is connected to an insulated conductor lead for connecting purposes. The wire contacts or brushes provide continuous pressure onto the contact rings of a slip ring rotor maintaining a passive electrical connection.

The Printed Circuit Brush Block Assembly P/N 6455149000 is a printed circuit board (PCB) measuring approximately 2½ inches by 8½ inches and is slightly less than ¼ inch thick. Mounted onto the top of the printed circuit board are four electrical connectors, two set-screw plastic connectors and two plug-in plastic connectors. The plug-in connectors are soldered to two conductor elements obtained during the printing process in the manufacturing of the PCB. The two set-screw connectors are attached to the printed circuit board with screws. The bottom of the PCB features four spring-like wire contacts or brushes soldered into two conductor elements and a four-channel plastic insulated fitting. Two of the channels contain a metal strip screwed onto the PCB. Each metal strip features four spring-like wire contacts or brushes soldered onto the strips. The plastic channel and metal contact strips are mounted to the PCB with screws. Some of the screws have a protective epoxy coating on them.

In your letter you suggest classification under heading 8538, Harmonized Tariff Schedule of the United States (HTSUS), as parts principally used with apparatus of headings 8535, 8536 or 8537, HTSUS. However, the Slip Ring Assembly P/N 6023242, Brush Block Assembly P/N 4994020000 and P/N 4990004000 each meet the term “apparatusfor making electrical connections to or in electrical circuits” under heading 8536, HTSUS. In the case of the Printed Circuit Brush Block Assembly P/N 6455149000, this item is a printed circuit board fitted with non-printed connecting elements for the connection of electrical components not obtained during the printing process. Although it is called a Printed Circuit Brush Block Assembly, it is an unpopulated printed circuit board, which does not contain discrete active components. As such, it is not a printed circuit assembly, but rather a bare printed circuit board of heading 8534, HTSUS.

The applicable subheading for the Slip Ring Assembly P/N 6023242, Brush Block Assemblies P/N 4994020000 and P/N 4990004000 will be 8536.90.8085, HTSUS, which provides for “Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuitsfor a voltage not exceeding 1,000 V: Other Apparatus: Other: Other.” The general rate of duty will be 2.7 percent ad valorem.

The applicable subheading for the Printed Circuit Brush Block Assembly P/N 6455149000 will be 8534.00.00, HTSUS, which provides for “Printed circuits.” The general rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Thomas Campanelli at 646-733-3016.

Sincerely,

Robert B. Swierupski
Director,

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