The tariff classification of electrical splices from Mexico

N337990 March 5, 2024 CLA-2-85:OT:RR:NC:N2:220 CATEGORY: Classification TARIFF NO.: 8536.90.4000 Michael Jessup TE Connectivity 1315 Charles Ave Charlotte, NC  28205                                                                                                                 RE:      The tariff classification of electrical splices from Mexico Dear Mr. Jessup: In your letter dated February 6, 2024. you requested a tariff classification ruling. There are three items under consideration that are referred to as Solder Sleeve Shield Terminations.  The first item, identified as the Solder Sleeve, PN 775210N006, consists of a heat-shrinkable insulation sleeve made of polyvinylidene fluoride, a solder preform ring with flux, and meltable rings made of thermoplastic material.   The second item under consideration is identified as the Solder Sleeve, PN 065762-000, which consists of a heat-shrinkable insulation sleeve made of polyvinylidene fluoride, a solder preform ring with flux, meltable rings made of thermoplastic material, and a conductive braid that extends from the splice body.  The third item under consideration is identified as the Solder Sleeve, PN 450705-000, which consists of a heat-shrinkable insulation sleeve made of polyvinylidene fluoride, a solder preform ring with flux, meltable rings made of thermoplastic material, and a conductive wire that extends from the splice body.  In use, the subject Solder Sleeves are used to make an environment resistant electrical ground connection to the shielding of an existing electrical wire and/or cable assembly.  Once the existing electrical conductor is prepared, the sleeve is fitted over the shield and heat is applied to shrink the sleeve and make a soldered connection.  We would note that the subject splices are rated at less than 1,000 V. In your request, you suggest the Solder Sleeve, PN 775210N006, is classifiable under subheading 8536.90.4000, Harmonized Tariff Schedule of the United States (HTSUS), and explain that this tariff classification is applicable to electrical splices without the ground connecting wire.  We agree.  However, you also suggest that the other splices, namely Solder Sleeves PN 065762-000 and PN 450705-000, which both have the grounding wire, should be classified under subheading 8544.42.9090, HTSUS.  We disagree. While the Solder Sleeves PN 065762-000 and PN 450705-000 do have a short length of wire, the wire acts solely as an electrical connector and not as an insulated conductor of heading 8544, HTSUS.  It is the opinion of this office that the addition of the wires do not change the character of the Solder Sleeves as splice connectors.  Further, the ground wire is not of equal importance to the finished article as it is not continuously used to conduct electricity.  As such, classification under heading 8544, HTSUS, is not applicable. The applicable subheading for the Solder Sleeves, PN 775210N006, PN 065762-000, and PN 450705-000, will be 8536.90.4000, HTSUS, which provides for “Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits (for example, switches, relays, fuses, surge suppressors, plugs, sockets, lamp-holders and other connectors, junction boxes), for a voltage not exceeding 1,000 V…: Other apparatus: Terminals, electrical splices and electrical couplings…”  The general rate of duty will be 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 the World Wide Web at https://hts.usitc.gov/current. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1).  This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. 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