The tariff classification of heat trace cables from ChinaMr. Michael E. RollPisani & Roll LLP1875 Century Park East, Suite 600Los Angeles, CA 90067

N288617 August 25, 2017 CLA-2-85:OT:RR:NC:N4:410 CATEGORY: Classification TARIFF NO.: 8516.80.8000 RE: The tariff classification of heat trace cables from China Mr. Michael E. Roll Pisani & Roll LLP 1875 Century Park East, Suite 600 Los Angeles, CA 90067 Dear Mr. Roll: In your letter dated July 25, 2017, on behalf of your client Pentair Technical Solutions (a division of Pentair plc), you requested a tariff classification ruling. The product under consideration is the Pentair’s XTV self-regulating heat trace cables. The XTV family of self-regulating heat trace cables provides solutions for industrial pipe freeze protection and process temperature maintenance applications requiring high power output. An XTV heating cable consists of two 14 AWG nickel-plated copper bus wires, separated by a fluoropolymer spacer and helically wrapped with a self-regulating fluoropolymer fiber that controls power output so that the cable has an unconditional temperature identification number (T-rating) of T2C (446°F or 230°C) or lower without use of thermostats. The XTV heat trace cables will be imported in varying cut to length sizes according to the customer’s need, as well as in bulk for stock distribution. The applicable subheading for the cut to length Pentair’s XTV self-regulating heat trace cables will be 8516.80.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides, in relevant part, for: "[E]lectric heating resistors, other than those of heading 8545; parts thereof: Electric heating resistors: Other." The general rate of duty is 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 https://hts.usitc.gov/current. Your inquiry does not provide enough information for us to give a classification ruling on the XTV heat trace cables imported in bulk for stock distribution. Your request for a classification ruling should include samples and detailed components breakdown of the product. 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 Hope Abada at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division