The tariff classification of a light controller from China

N296765 May 24, 2018 CLA-2-85:OT:RR:NC:N2:220 CATEGORY: Classification TARIFF NO.: 8537.10.9170 Ryan Supek TE Connectivity Corporation 2800 Fulling Mill Road Middletown, PA 17057 RE: The tariff classification of a light controller from China Dear Mr. Supek: In your letter dated May 4, 2018 you requested a tariff classification ruling. The item under consideration is identified as the “LUMAWISE Endurance N Enhanced Base”, (Controller), which consists of a printed circuit board assembly (PCBA) mounted to a plastic base. The PCBA contains rectifying circuitry, three multi-pin connectors, relays, AC switching circuits, and communication/control electronics that enable the device to control and provide power to outdoor lighting. You state that its primary function is to serve as a power supply and a switching unit to the outdoor lighting, with the Controller supplying 24V, 5V, and 3.3V DC to the connected lights. In your request you have proposed classification of the Controller in subheading 8504.40.9510, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. Note 3 to Section XVI states that machines designed for the purpose of performing two or more complementary or alternative functions are to be classified as if consisting only of that component which performs the principal function. As noted above, the subject base is said to have two functions. The first is to electrically control lighting from another location and the second is to rectify and provide power to the attached lights. As the submitted literature explains, the Controller is a platform for the development and manufacture of NEMA/ANSI street and outdoor lighting control solutions. This base is suitable for control of luminaires using the ANSI/NEMA C136-style photo control receptacle. It offers zero-cross switching to manage the high-inrush current of LED luminaires and supports other lighting technologies. It is the opinion of this office that the Controller executes a function of electrical control that would place its classification outside of heading 8504. As such, subheading 8504.40.9510, HTSUS, would be inapplicable. We would note that the Controller consists of a base with a PCBA having multiple apparatus that are classifiable in heading 8536, HTSUS, such as the relays, the connectors, and the AC switching circuits. And, as the principal function of the Controller is the electric control or the distribution of electricity, the Controller would directly meet the requirements for heading 8537, HTSUS, and will be classified accordingly. The applicable subheading for the LUMAWISE Endurance N Enhanced Base will be 8537.10.9170, 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 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 https://hts.usitc.gov/current. 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 Karl Moosbrugger at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division