The tariff classification of a lighting management unit (LMU) from the People’s Republic of China

N233465 October 15, 2012 CLA-2-85:OT:RR:NC:N1:109 CATEGORY: Classification TARIFF NO.: 8504.40.9580 Mr. Alfred Xin Maridiano 360/DBA Luxtech 360 6995 Paddison Road Cincinnati, OH 45230 RE: The tariff classification of a lighting management unit (LMU) from the People’s Republic of China Dear Mr. Xin: In your letter dated September 18, 2012 you requested a tariff classification ruling. The merchandise subject to this ruling is a lighting management unit (LMU). The LMU uses electronic devices, isolated gate bipolar transistor (IGBT) modules which have high frequency turn-on and turn-off switches, several thousands times of switching on and off per second, to adjust the input alternating current (AC) and by adjusting the height of the electrical waves and by only select positive pure sine from the waves, the system reduces voltage levels and achieves the purpose of energy saving. As such, it is a high capacity and voltage dimmer that does not use traditional copper wired transformers. Rather, it adjusts the voltage by the high frequency turn-on and turn-off of the power semiconductor device, the IGBT module. The LMU is used in city streets and at interstate high intersections, parking lots, and yard depots where the light lamps are high-pressure gas discharge lamps, such as high-pressure sodium lamps, metal halide lamps, and mercury vapors. For instance, an auto dealer can program the LMU to provide a 15 percent energy savings of light usage for a car lot during the evening hours of 6:00 p.m. – 9:00 p.m. and from 9:00 p.m. – 7:30 a.m., when sales people and customers will not be walking within the car lot., the car dealer can program the LMU to provide 45 percent energy savings, which means that the lights will be further dimmed. The applicable subheading for the light management unit (LMU) will be 8504.40.9580 Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical transformers, static converters (for example, rectifiers) and inductors: parts thereof: Static converters: Other: Other.” 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, Thomas J. Russo Director National Commodity Specialist Division