The tariff classification of HVAC cable from China

N332833 May 25, 2023 CLA-2-85:OT:RR:NC:N2:212 CATEGORY: Classification TARIFF NO.: 8544.42.9090; 9903.88.03 Reina Okada Flobal Corporation 14th Flr, Tatsunonishihonmachi Bldg, 1-15-10 Nishihonmachi, Nishi WardOsaka 5500005Japan RE: The tariff classification of HVAC cable from China Dear Ms. Okada: In your letter dated May 9, 2023, you requested a tariff classification ruling. The merchandise at issue with this request is identified by the two part numbers A-14AWG4C18 and A-14AWG4C27, and is described as an air conditioning communication cable. The cables are constructed identically with the difference being that the first is imported at a length of 18 feet while the second is presented at a length of 27 feet. The cables are constructed of four separately insulated copper conductors bundled together and further insulated with PVC. The end of each conductor is affixed with varying styles of terminal connectors. You state that the finished cables are rated at 600V. You state that the finished cables are used to connect an outdoor air conditioning compressor to an indoor evaporation unit in a ductless air conditioning system. The cable sends electrical power and electrical control signals between the two units. Though described as a communication cable, we find that the electrical control signals conducted via the cable are not considered telecommunications signals for classification purposes. The applicable subheading for the air condition communication cables, part numbers A-14AWG4C18 and A-14AWG4C27 will be will be 8544.42.9090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Insulated (including enameled or 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: Fitted with connectors: Other: Other: Other.” The general rate of duty will be 2.6% ad valorem. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8544.42.9090, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8544.42.9090, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading.  For background information regarding the Section 301 trade remedy, you may refer to the relevant parts of the USTR and CBP websites, which are available at:   https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions https://www.cbp.gov/trade/remedies/301-certain-products-china 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 at https://hts.usitc.gov/current This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Luke LePage at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division