Charge-Guard Adjustable Wrist Strap; electrical apparatus for protecting electrical circuits

HQ 088063 January 9, 1991 CLA-2 CO:R:C:G 088063 JMH CATEGORY: Classification TARIFF NO.: 8536.30.00 Mr. Thomas C. Lloyd Customs Administrator 3M Logistics P.O. Box 33800 St. Paul, MN 55133-3800 RE: Charge-Guard Adjustable Wrist Strap; electrical apparatus for protecting electrical circuits Dear Mr. LLoyd: Your September 10, 1990 request for a classification ruling regarding the 2200 series Charge-Guard Adjustable Wrist Strap imported from Mexico has been forwarded to this office for a reply. FACTS: The articles in question are the 2200 series Charge-Guard Adjustable Wrist Strap which are imported from Mexico. The wrist strap consists of a wrist band, a coil cord, and a banana plug or an alligator clip. The wrist band is made of knitted polyester with spandex and a silver plated nylon thread. The wrist band has a plastic/metal snap for attachment to the cord. The metal base of the snap lies flat on the wearer's wrist. A 1-megohm resistor is molded into the snap. The cord is made of a single bundle of tinsel conductor laced into high strength, synthetic fibers. The snap fastener is on one end of the cord. The other end of the cord has a banana plug or alligator clip that attaches to a conductive table or floor mat to "ground" any static charge flowing through the cord and strap. The Wrist Strap is used for safety purposes to protect the wearer from inadvertently coming into contact with up to 240 volts. However, typically the Wrist Strap is used by repair technicians to protect printed circuit boards and static sensitive electronic devices from static charges. The Wrist Strap "grounds" the technician repairing the electronic device from any static charge that would otherwise occur. -2- ISSUE: What is the appropriate classification for the 2200 series Charge-Guard Adjustable Wrist Strap. LAW AND ANALYSIS: The classification of merchandise under the Harmonized Tariff Schedule of the United States Annotated ("HTSUSA") is governed by the General Rules of Interpretation ("GRIs"). GRI 1, HTSUSA, states in part that "for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes..." The Wrist Strap acts to collect static charges that could damage printed circuit boards and then disperses the charge to ground. The Wrist Strap protects printed circuit boards and other electrical apparatus from damaging current. By its operation the Wrist Strap meets the terms of heading 8536, HTSUSA, as an electrical apparatus that protects electrical circuits. The proper classification for the Charge-Guard Adjustable Wrist Strap is subheading 8536.30.00, HTSUSA, as "Electrical apparatus for...protecting electrical circuits...for a voltage not exceeding 1,000 V...Other apparatus for protecting electrical circuits..." HOLDING: The Charge-Guard Adjustable Wrist Strap protects electrical apparatus from damage caused by static electricity and other stray current. In accordance with GRI 1, the Wrist Strap meets the terms of heading 8536. The proper classification for the Charge-Guard Adjustable Wrist Strap is subheading 8536.30.00, HTSUSA, as "Electrical apparatus for...protecting electrical circuits...for a voltage not exceeding 1,000 V...Other apparatus for protecting electrical circuits..." Sincerely, John Durant, Director Commercial Rulings Division