The tariff classification of Delta Modules from the United Kingdom

N169780 July 5, 2011 CLA-2-85:OT:RR:NC:N1:109 CATEGORY: Classification TARIFF NO.: 8504.40.9570 Mr. David Soyka, Esq. Sr. Manager, Export Control & Customs Siemens Energy, Inc. 4400 Alafaya Trail Orlando, FL 32826 RE: The tariff classification of Delta Modules from the United Kingdom Dear Mr. Soyka: In your letter dated May 31, 2011, you requested a tariff classification ruling. The merchandise subject to this ruling is referred to in your submission as Delta Modules. They are identified as MV3000. The MV3000 Delta Modules are used in wind turbine generator sets to convert direct current (DC) coming out of the generator into alternating current (AC), which is supplied to an electrical grid. As such, the MV3000 Delta modules are inverters (DC/AC). Each MV3000 Delta Module consists of 3 SKiiP modules (IGBT), a capacitor bank, 3 snubber capacitors boards, busbars, and some interface printed circuit boards. An MV3000 Delta Module is the module that forms a power bridge consisting of a machine bridge and a mains bridge. In order to achieve the power level needed the MV3000 Delta Modules are used in parallel for each bridge. For a 2.3MW converter 3 sets of modules are used in parallel and the total is thereby 6 modules. The machine bridge controls the power generated at variable frequency in an induction generator and transfers it to a DC link. It responds to changes in the wind and adjusts its control to deliver the power required of it. In the process, the power is converted to DC. The mains bridge takes the DC link power and converts it into fixed frequency AC suitable for acceptance into an electrical grid. It delivers this power to the grid with low harmonic distortion. Reactive current can also be simultaneously controlled by the mains bridge. The applicable subheading for the Delta Modules (MV3000) will be 8504.40.9570, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electrical transformers, static converters and inductors; parts thereof: Static converters: Other; Inverters,” The rate of duty will be 1.5 percent ad valorem. 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 Linda M. Hackett at (646) 733-3015. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division