The tariff classification of an insulating washer

N032380 July 29, 2008 CLA-2-85:OT:RR:NC:N1:112 CATEGORY: Classification TARIFF NO.: 8547.20.0000 Danivia Vasconcelos, C.C.S Certified Customs & Traffic Manager RCP Inc. 2891 Langstaff Road Concord, Ontario, Canada L4K 4Z2 RE: The tariff classification of an insulating washer Dear Ms. Vasconcelos: In your letter dated June 24, 2008, you requested a tariff classification ruling. The item concerned is an insulating washer (Part # 23633). This circular shaped insulator has an inner diameter of 0.520 inches and an outer diameter of 1.200 inches. It is yellow in color and comprised of glass polyester. The insulator will be used in 37MT and 42MT starter motor assemblies. These starter motors incorporate a copper stud that is connected to the electrical circuitry inside the motor. The copper stud passes through a hole in the starter motor frame and is connected to a solenoid lead wire. This copper stud must be insulated from the starter frame; a series of insulating bushings is used to accomplish that task. The copper stud is fixed to the starter frame by means of a hex nut. Due to the fact that the hex nut is in intimate contact with the copper stud, it is also an electrically live component which needs to be insulated from the starter frame. In order to insulate the hex nut from metal starter frame, this insulating washer is placed between the hex nut and the starter frame. The purpose of this insulating washer is to insulate the live stud/hex nut from the grounded frame. You proposed classification under subheading 8546.10.00.00, Harmonized Tariff Schedule of the United States (HTSUS) which provides for “Electrical insulators of any material: Of glass.” However, it is the opinion of this office that the insulator (Part # 23633) is more specifically provided for in subheading 8547, which provides for “Insulating fittings for electrical machines…:” The applicable subheading for the insulator (Part # 23633) will be 8547.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Insulating fittings for electrical machines, appliances or equipment, being fittings wholly of insulating material…: Insulated fittings of plastics.” 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