The tariff classification of a voltage regulator from China

N152495 April 5, 2011 CLA-2-85:OT:RR:NC:N1:109 CATEGORY: Classification TARIFF NO.: 8504.40.95 Mr. Charles C. Parisi Parisi Services, Inc. Customs Brokerage & Freight Forwarding P.O. Box 91217 Los Angeles, CA 90009 RE: The tariff classification of a voltage regulator from China Dear Mr. Parisi: In your letter dated March 1, 2011 you requested a tariff classification ruling on behalf of your client, Ingenium sourcing Partners, Inc. The merchandise subject to this ruling is a voltage regulator. It is identified within your letter as Item # ING102026A. This voltage regulator will be placed in various models of aroma oil diffusers and air fresheners. It will modulate the operating voltage of a heating element and indicate whether the diffusers or air fresheners are in the “ON” state through use of the LEDs connected to this device. A sample of the voltage regulator was furnished for classification purposes and is being returned to you as per your request. The voltage regulator consists of two printed circuit assemblies connected together with electrical wire. The exploded views submitted reveals that one of the printed circuit assemblies, identified as Board 1 and entitled “Dimmer circuit and adjustment potentiometer”, consists of a capacitor, resistors, diodes, a triac, a potentiometer, trimpots, and a diac. The second printed circuit assembly, identified as Board 2 and entitled “Lighting and connections”, consists of a capacitor, LEDs, resistors, a fuse, and terminals. These connected boards will be placed into aroma oil diffusers and air fresheners. Once inserted into the diffusers and air fresheners, the boards will be connected to an electrical cord that will plug into an alternating current wall outlet. When in use, Item # ING102026A will modulate the operating voltage of the heating element within the diffusers and air fresheners and convert the alternating current to direct current in order to illuminate the LEDs to indicate when the diffusers and air fresheners are in the “ON” mode. Based on the functioning of the voltage regulator, it is a rectifier in accordance with Explanatory Note (EN) 85.04 (II) (A), which states: “This group includes: Rectifiers by which alternating current is converted to direct current, generally accompanied by a voltage change.” The fact that this device includes various other devices, such as resistors or auxiliary circuits, does not affect the classification as a rectifier as EN 85.04 (II) states: “The apparatus of this group are used to convert electrical energy in order to adapt it for further use. They incorporate converting elements of different types. They may also incorporate various auxiliary devices (e.g., transformers, induction coils, resistors, command regulators, etc.)… The fact that these apparatus often incorporate auxiliary circuits to regulate the voltage of the emerging current does not affect their classification in this group, nor does the fact that they are sometimes referred to as voltage or current regulators.” The applicable subheading for the voltage regulator (Item # ING102026A) will be 8504.40.95, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical transformers, static converters (for example rectifiers) and inductors; parts thereof: Static converters: Other: Rectifiers and rectifier apparatus: Power supplies.” The rate of duty will be 1.5 percent ad valorem. 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 Linda M. Hackett at (646) 733-3015. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division