The tariff classification of a membrane switch unit and a key sheet unit from Thailand

NY H86009 January 2, 2002 CLA-2-85:RR:NC:1:112 H86009 CATEGORY: Classification TARIFF NO.: 8537.10.9070 Ms. Fusae Nara Pillsbury Winthrop LLP One Battery Plaza New York, NY 10004-1490 RE: The tariff classification of a membrane switch unit and a key sheet unit from Thailand Dear Ms. Nara: In your letter dated December 3, 2001, on behalf of Sharp Manufacturing Company, you requested a tariff classification ruling. As indicated by the submitted samples and information, there are two items in question. The membrane switch is comprised of a number of push button type switches, a ribbon connector, and membrane, all of which are affixed to a flexible printed circuit. This is eventually incorporated into the control panel of a microwave oven. The applicable subheading for the membrane switch unit will be 8537.10.9070, Harmonized Tariff Schedule of the United States (HTS), which provides for other boards, panels, … and other bases, …, for electric control or the distribution of electricity: For a voltage not exceeding 1,000 V. The rate of duty will be 2.7 percent ad valorem. This rate of duty will remain unchanged in 2002. Articles classifiable under subheading 8537.10.9070, HTS, which are products of Thailand, are currently entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations. The GSP, however, is subject to modification and periodic suspension, which may affect the status of your transaction at the time of entry for consumption or withdrawal from warehouse. To obtain current information on GSP, check the Customs Web site at www.customs.gov. At the Web site, click on "CEBB" and then search for the term "T-GSP". Your inquiry does not provide enough information for us to give a classification ruling on the key sheet unit. Your request states that this is identical to the membrane switch and merely incorporates the graphic keyboard overlay. An examination of the sample indicates that the key switch unit is simply the graphic overlay. Is there anything electrical about the key sheet unit, or is it only the flexible overlay? If only the overlay, what material is it comprised of? When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you. 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 David Curran at 646-733-3017. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division