The tariff classification of a Magnetohydrodynamics (MHD) Unit

NY L83876 April 27, 2005 CLA-2-85:RR:NC:MM:109 L83876 CATEGORY: Classification TARIFF NO.: 8505.11.0000 Mr. John H. Meckling President Meckling’s MHD Systems, Inc. P.O. Box 667 Bogalusa, LA 70429-0667 RE: The tariff classification of a Magnetohydrodynamics (MHD) Unit Dear Mr. Meckling: In your letter dated March 29, 2005, you requested a tariff classification ruling. The merchandise subject to this ruling is a Magnetohydrodynamics (MHD) Unit. The MHD unit is a strong permanent magnet. It consists of a stainless steel housing which contains a magnet assembly. The magnet assembly is composed of the metallic elements aluminum, nickel, and cobalt (ALNICO). The function of the MDH Unit is to prevent scale from being deposited in pipes, evaporators, heat exchangers, and other types of scale-prone equipment and to facilitate the removal of existing scale deposits. It does this by using the science of Magnetohydrodynamics to generate an energy state in the conductive elements contained in the water. The MHD Units are self-contained water treatment devices that alter the scaling characteristics of aqueous fluids by causing the minerals, which are dissolved or suspended, in the fluids to interact with intense magnetic fields. Although they are utilized in water treatment systems, they do not trap, lift, or magnetize. The interaction of the minerals with the intense magnetic fields modifies the bond angles of minerals when they drop out of the water, whereby changing the bond angles so they do not adhere to the heat transfer surfaces, thus keeping the surfaces clean. The mineral salts, which normally produce scale in aqueous systems, undergo complex chemical and physical changes within and downstream of the MHD Unit as a result of interaction with an intense magnetic field. When a conductor or electricity moves through a magnetic field, an electromotive force is produced. In electrical generators this force causes electrical current flow. In aqueous solutions, this force causes dissolved or suspended minerals to undergo changes in surface charge, particle size, crystalline morphology, and solubility, which alter their ability to produce scale. The result is generation of a fluid that contains particles that are not only reluctant to precipitate as scale, but which can also attack and dissolve existing scale downstream of the treatment unit. The applicable subheading for the Magnetohydrodynamics (MHD) Unit, will be 8505.11.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Permanent magnets and articles intended to become permanent magnets after magnetization: Of metal”. The general rate of duty will be 2.1 percent ad valorem. 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 Linda M. Hackett at 646-733-3015. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division