The tariff classification of a controller from China.

N158995 April 28, 2011 CLA-2-85:OT:RR:NC:1:110 CATEGORY: Classification TARIFF NO.: 8537.10.9070 Mr. Bob Sanshuk C.H. Robinson International, Inc. 1800 Nicholas Blvd. Elk Grove Village, IL 60007 RE: The tariff classification of a controller from China. Dear Mr. Sanshuk: In your letter dated April 4, 2011, you requested a tariff classification ruling on behalf of your client, TKJ, Incorporated. The items under consideration are two domestic oven controllers identified as models ES20028 and VR20021. From the information you provided, model ES20028 is an electric oven controller consisting of a printed circuit board (PCB) populated with active and passive components. These components include 3 electromechanical relays, 5 push-button switches, 5 indicator lights, a transformer and a clock. The relays supply 220 VAC (volts/alternating current) power to various components within the oven. They provide on/off power to the oven light, power to an electric motor that cycles a door latch between the ‘locked’ and ‘unlocked’ position used in the cleaning mode and master power to the ovens thermostat and the ovens heating elements for cooking. These functions are not dependent on the clock mechanism. The clock is a generic timer used for timing anything. When in cleaning mode, the controller will provide power to the door lock relay until the oven door indicates a locked condition. The controller will then provide power to the thermostat until the cleaning process is complete. Upon completion, the controller will open the electrical circuits, disconnecting power to the thermostat and heating elements. When the oven has cooled sufficiently, the controller will power the door lock relay until the oven door indicates an unlocked position. Model VR20021 is an electric oven controller consisting of a PCB populated with active and passive components. These components include 1 electromechanical relay, 4 push-button switches, one rotary switch, a transformer and a clock. From the information you provided, the VR20021 is a component of a larger control panel and controls one relay that switches 220 VAC to the thermostat and heating elements. It does not control the oven cavity temperature, which is handled by an external thermostat. The applicable subheading for the ES20028 controller will be 8537.10.9070, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or the 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. 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/. Your inquiry does not provide enough information for us to give a classification ruling on the VR20021 model. Your request for a classification ruling should include the following material: Please furnish a sample of model VR20021 with all components labeled.  Are any of the functions performed by model VR20021 unrelated to time?  If so, what are these functions?  Does model VR20021 contain only one relay?  What function does that relay perform? You state that model VR20021 controls cooking by applying or removing the power to the master thermostat and heating elements.  Please explain in more detail.  Does this involve the time function? When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you. 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