The tariff classification of Solar Generator Model PowerHub 1800

N181095 September 15, 2011 CLA-2-85:OT:RR:NC:N1:109 CATEGORY: Classification TARIFF NO.: 8507.20.80 Mr. Sean Cole Solutions from Science 815 West Main Street P.O. Box 518 Thomson, IL 61285 RE: The tariff classification of Solar Generator Model PowerHub 1800 Dear Mr. Cole: In your letter, which was received by this office August 18, 2011, you requested a tariff classification ruling. The merchandise subject to this ruling is a Solar Generator Model PowerHub 1800. It consists of a solar charging module, two solar panels, and two 100 amp/hour, lead acid, AGM deep cycle rechargeable batteries. Attached at the back of each solar panel is a junction box with a terminal block within it. The terminal block has a power cord connected to it. The lead acid, AGM deep cycle rechargeable batteries are sealed within the battery casing of the PowerHub 1800. The casing of the PowerHub 1800 also contains an inverter. The PowerHub 1800 is fully wired and ready to use as a plug and play power generating system. It is prewired for up to 200 watts of power enabling the user to charge the system’s batteries with the solar panels or from household alternating current (AC). As such, the user can plug the solar panel cable into the Anderson power socket on the main unit to obtain power. All wires are enclosed inside the main unit except for the 120 volts alternating current (VAC) power cord and the solar panel connection cord, which is equipped with an Anderson power plug. The Solar Generator Model PowerHub 1800 can easily be moved from place to place for a variety of uses in and away from home, such as while camping, boating, and for remote power for construction sites. The solar charging module permits the solar panels to charge/recharge the lead acid rechargeable batteries. The rechargeable batteries are used to draw up to the 1800 watts available to power many 110 voltage household appliances, such as, televisions, radios, refrigerators, freezers and lights. The rechargeable batteries for the Solar Generator Model PowerHub 1800 can be recharged in one of two manners, i.e. by the solar panel or by a built-in alternating current (AC) charger. The two 150 watt solar panels are used to recharge the batteries within the PowerHub 1800 casing. The silicon cells that comprise the solar panel absorb photons from sunlight and convert them to direct current (DC) electricity. The DC flow is carried on aluminum ribbons that come together within the terminal block enclosed within the junction box on the back of the solar panel. The terminal block is connected to the 100 foot 12-3 cord that has a 5L-20P power connector attached to the end of the cord. You explained within your submission that the solar panels would absorb photons from sunlight and convert them into DC electricity. The DC electricity would be transmitted along a wire to a solar charging module which would charge the lead acid deep cycle batteries. At that point, a load would be drawn and the energy would be inverted to a modified AC wave of up to 1800 watts. The unit would then be able to provide power to various 110 VAC household appliances and could also function as an uninterruptable power supply (UPS) when the unit is plugged into a 120 VAC receptacle utility grid. A photograph of the Solar Generator Model PowerHub 1800 identifies the system as two stand-alone solar panels, which appears to incorporate a solar charging module, and the casing for the PowerSource 1800, which you stated contains the two lead acid rechargeable batteries. The solar panel/solar charging module and the PowerHub 1800 casing, containing the lead acid rechargeable batteries, constitute a retail set because they are classified in separate headings, work together to charge electrical devices, and the articles are packaged together for retail sale. The solar panel/solar charging module generates electricity and charges electrical devices, as a electric generator of heading 8501. The lead acid rechargeable batteries, within the PowerHub 1800 casing, store electricity and charge electrical devices, as rechargeable batteries of heading 8507. As was determined within headquarters’ Ruling H136116, which ruled upon similar merchandise, specifically a Sherpa Power Pack and a Nomad Solar Panel, since both functions are equally important, we cannot determine which article provides the essential character. Therefore, in accordance with General Rule of Interpretation (GRI) 3(c), the entire Solar Generator Model PowerHub 1800 system will be classified as a rechargeable battery under heading 8507, the heading that occurs last in numerical order among those which equally merit consideration. The applicable subheading for the Solar Generator Model PowerHub 1800 will be 8507.20.80, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric storage batteries, including separators therefor, whether or not rectangular (including square): parts thereof: Other lead-acid storage batteries: Other.” The rate of duty will be 3.5 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