The tariff classification of strain relief housings from China

N216155 May 23, 2012 CLA-2-76:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7616.99.5090 Mr. John M. Peterson Neville Peterson LLP Counsellors at Law 17 State Street, 19th Floor New York, NY 10004 RE: The tariff classification of strain relief housings from China Dear Mr. Peterson: In your letter dated April 26, 2012, on behalf of Amphenol Optimize Manufacturing Co. Inc., you requested a tariff classification ruling on strain relief housings. A sample and description of the subject housings were submitted for our review. You indicated in your letter that the merchandise that you plan to import consists of strain relief housings for electrical connectors, which are imported into the United States in an unassembled condition. The housings in question, identified as part number U10-584185-143, are used to protect electrical wire and circuit connections by providing strain relief against the twisting or pulling action of a wire or cordset. Strain relief housings come in various sizes and configurations. The subject merchandise provides wire isolation protection for wiring assemblies and connections, isolates products from electric shock and prevents wires from being pulled out of junction boxes or electrical connectors. Each strain relief housing under consideration consists of a molded aluminum jacket that measures approximately 1 inch in height and 5/8 inch in diameter at its widest point. A circular opening that measures approximately 3/8 inch is molded into the bottom portion of the jacket. The strain relief housing features a nylon plastic insert which is designed to be placed into the jacket. The jacket is typically lined with a molded plug. You stated that the jacket and plug are packaged and shipped to the United States with two clamp bars that feature holes drilled at each end and two screws that measure 5/8 inch in length. Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is governed in accordance with the General Rules of Interpretation (GRI’s). GRI 2(a) states that “Any reference in a heading to an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as entered, the incomplete or unfinished article has the essential character of the complete or finished article. It shall also include a reference to that article complete or finished (or failing to be classified as complete or finished by virtue of this rule), entered unassembled or disassembled.” You indicated in your letter that Amphenol Optimize Manufacturing Co. Inc. noted that the merchandise in its condition as imported consists of a single article which is imported in an unassembled condition. Each package at the time of importation into the United States contains the components needed to make one strain relief housing. GRI 2(a) to the HTSUS provides that an article imported unassembled is to be classified as if it were the finished article. Since the jacket and molded plug are packaged and shipped to the United States with the two clamp bars and two screws, our office agrees with the analysis that the various imported components constitute an unassembled article and therefore, should be classified as if it were a finished strain relief housing. You proposed classification for the aluminum strain relief housings under subheading 8536.30.80, HTSUS, and alternately subheading 8538.90.60 or subheading 7616.99.50, HTSUS. Heading 8536, HTSUS, is limited to apparatus for switching or protecting electrical circuits or for making connections to electrical circuits. This aluminum strain relief housing simply relieves the stress of individual connectors by maintaining a grip on the outer jacket of the cable. This article is also excluded from heading 8538 which covers parts for headings 8535, 8536 and 8537, HTSUS, for the same reason. Therefore, the aluminum strain relief housings are classifiable under heading 7616, HTSUS, which provides for other articles of aluminum. The applicable subheading for the aluminum strain relief housings will be 7616.99.5090, HTSUS, which provides for other articles of aluminum, other, other…other. The rate of duty will be 2.5 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 Ann Taub at (646) 733-3018. Sincerely, Thomas J. Russo Director National Commodity Specialist Division