Ductile Cast Iron Parts for Electrical Insulators; 8546.20.00

HQ 954182 September 8, 1993 CLA-2 CO:R:C:M 954182 DWS CATEGORY: Classification TARIFF NO.: 7325.99.10 Mr. Gene D. Smith G.S. Consultants One Park Place, Suite 250 621 N.W. 53rd Street Boca Raton, FL 33487 RE: Ductile Cast Iron Parts for Electrical Insulators; 8546.20.00 Dear Mr. Smith: This is in response to your letter of May 7, 1993, concerning the classification of ductile cast iron parts under the Harmonized Tariff Schedule of the United States (HTSUS). FACTS: The merchandise consists of ductile cast iron parts (model no. 6545-12) for electrical ceramic insulators. These parts are solely used in telephone poles with insulator caps for the purpose of hanging wire from the telephone poles. The subheadings under consideration are as follows: 8546.20.00: [e]lectrical insulators of any material: [o]f ceramics. The general, column one rate of duty is 6 percent ad valorem. 7325.99.10: [o]ther cast articles of iron or steel: [o]ther: [o]ther: [o]f cast iron. The general, column one rate of duty is 3.1 percent ad valorem. ISSUE: Whether the ductile iron parts are classifiable under subheading 8546.20.00, HTSUS, as electrical ceramic insulators, or under subheading 7325.99.10, HTSUS, as other articles of cast iron? FACTS: Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation (GRI's), taken in order. GRI 1 provides that classification is determined according to the terms of the headings and any relative section or chapter notes. The ductile iron parts are not classifiable under subheading 8546.20.00, HTSUS, because the parts are not insulators themselves, but are parts of insulators. Heading 8546, HTSUS, does not contain a parts provision, nor is there a corresponding parts heading for heading 8546, HTSUS. The parts are, however, described under heading 7325, HTSUS. Therefore, because the parts are not specifically described elsewhere in the HTSUS, it is our position that they are classifiable under subheading 7325.99.10, HTSUS. HOLDING: The ductile cast iron parts are classifiable under subheading 7325.99.10, HTSUS, as other articles of cast iron. Sincerely, John Durant, Director