The tariff classification of a controller assembly.

N021447 January 17, 2008 CLA-2-85:OT:RR:E:NC:1:110 CATEGORY: Classification TARIFF NO.: 8537.10.9070 Mr. Russ Ledbetter Goodrich Corporation 4115 Corporate Center Drive Monroe, NC 28110 RE: The tariff classification of a controller assembly. Dear Mr. Ledbetter: In your letter dated January 3, 2008 you requested a tariff classification ruling. The merchandise under consideration is the Series Pendant Assembly, Part Number 465220. The Pendant Assembly controls the power drive units in the floor of an aircraft cargo bay, allowing the user to control the movement of pallets within the aircraft cargo bay. It consists of a rectangular hand-held metal housing equipped with a thumb controlled 4-way toggle switch, two lamp-holders outfitted with indicator lights, and a cylindrical multicontact connector on a short coiled wire that connects the assembly to the aircraft’s electrical cargo movement system. In your ruling request you suggest classification of the Pendant Assembly in 8537.10.6000, Harmonized Tariff Schedule of the United States (HTSUS), as a motor control center, or 8536.50.9065, HTSUS, as a switch. However, a motor control center is an assembly of one or more enclosed sections having a common power bus and principally containing motor control units. Therefore, the Pendant Assembly does not meet the common or commercial meaning of a motor control center. The Pendant Assembly is more sophisticated than a simple switch assembly and contains more that two items (switch, plug and two lamp-holders), individually classified in heading 8536, HTSUS. The applicable subheading for the Series Pendant Assembly, Part Number 465220 will be 8537.10.9070, HTSUS, which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Other.” The general rate of duty will be 2.7 percent ad valorem. 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, National Commodity Specialist Division