The tariff classification of a "starter brush holder insulator" and an "alternator insulator" from an unspecified country.

N014094 August 6, 2007 CLA-2-85:RR:NC:N1:112 CATEGORY: Classification TARIFF NO.: 8547.20.0000 Danivia Vasconcelos, C.C.S Certified Customs & Traffic Manager 2891 Langstaff Road Concord, Ontario, Canada L4K 4Z2 RE: The tariff classification of a “starter brush holder insulator” and an “alternator insulator” from an unspecified country. Dear Ms. Vasconcelos: In your letter received July 11, 2007, you requested a tariff classification ruling. The first item concerned is described as a “starter brush holder insulator”. This item consists of a flat stamped piece of rigid plastic/fiberglass material. It is orange/salmon in color and has an approximately 1 ½ inch circular hole in the center. This part is manufactured based on a specific geometric design for use in a brush holder assembly. This item acts to insulate live metal components from dead metal components within a starter motor. The second item concerned is described as an “alternator insulator”. This item is black in color and made from molded plastic. In use, this item would be mounted in an alternator for the purpose of separating and insulating the three phase leads from one another. You proposed classification under subheading 8511.90.6040 of the Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical ignition or starting equipment…: Parts: Other parts: Other”. This office is of the opinion that both of these items are provided for in heading 8547 which specifically provides for insulating fittings such as the ones at issue. The applicable subheading for the “starter brush holder insulator” and the “alternator insulator” will be 8547.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Insulating fittings for electrical machines…: Insulating fittings of plastics”. The 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 World Wide Web at http://www.usitc.gov/tata/hts/. 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 Steve Pollichino at 646-733-3008. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division