The tariff classification of data bus couplers from Mexico

N332161 April 19, 2023 CLA-2-85:OT:RR:NC:N2:220 CATEGORY: Classification TARIFF NO.: 8537.10.9170; 8544.49.2000 Rachael Barnes TE Connectivity 2801 Fulling Mill Road Middletown, PA  17057                                                                                 RE:      The tariff classification of data bus couplers from Mexico Dear Ms. Barnes: In your letter dated April 11, 2023, you requested a tariff classification ruling. The first item under consideration is identified as the D-500 Box Coupler, PN 14895-000, which is described as an aluminum enclosure having 10 externally mounted male bayonet connectors and four internal printed circuit board assemblies (PCBAs) that contain isolation resistors and transformers.  You state that the D-500 Box Coupler functions to interconnect multiple data bus lines but is a passive electrical connection where the signals are not altered. In your letter, you suggest the D-500 Box Coupler is classifiable under subheading 8537.10.9170, Harmonized Tarif Schedule of the United States (HTSUS).  We agree. The second item under consideration is identified as the D-500 In-Line Microcoupler, PN CN6196-000, which is described as an aluminum enclosure having a passive PCBA and approximately 20 feet of electrical cable attached to the ends.  The PCBA, which serves as the connection point for incoming and outgoing twisted pair cable wires, contains isolation resistors and a transformer.  You state that the D-500 In-Line Microcoupler functions to interconnect shielded twisted pair cables onto a data bus while not altering the electrical signals. In your letter, you suggest that the correct classification for the D-500 In-line Microcoupler is classified under subheading 8544.30.0000, HTSUS. We disagree. The suggested classification covers “ignition wiring sets and other wiring sets of a kind used in vehicles, aircrafts, or ships.”  Though you state that the subject device is used within a vehicle, we are of the opinion that it does not meet the definition of a wiring set.  In Headquarters Ruling Letter W967801, a wiring set was defined as wires grouped together to form a unit.  Based upon the information provided, there is only one wire that performs the electrical transmission.  As such, subheading 8544.30.0000, HTSUS, in not applicable in this instance. The applicable subheading for the D-500 Box Coupler, PN 14895-000 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 general rate of duty will be 2.7 percent ad valorem. The applicable subheading for the D-500 In-Line Microcoupler, PN  CN6196-000, will be 8544.49.2000, HTSUS, which provides for “Insulated (including enameled and anodized) wire, cable (including coaxial cable) and other insulated electric conductors, whether or not fitted with connectors; optical fiber cables, made up of individually sheathed fibers, whether or not assembled with electric conductors or fitted with connectors: Other electric conductors, for a voltage not exceeding 1,000 V: Other: For a voltage not exceeding 80 V: Other.”  The general rate of duty will be 3.5% 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 the 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