The tariff classification of palladium springs from the United Kingdom

N250018 February 24, 2014 CLA-2-71:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7115.90.6000 Mr. Miles W S Brennan Central Metals & Alloys Limited 13 Main Street Nuneaton Warwickshire, CV13 0DJ United Kingdom RE: The tariff classification of palladium springs from the United Kingdom Dear Mr. Brennan: In your letter dated January 28, 2014, you requested a tariff classification ruling. Photographs, drawings and descriptive literature were submitted for our review. The merchandise is described as palladium alloy precious metal springs for slip rings. You stated that “The spring is a semi-manufactured part formed in 0.007” wire and once received in the USA it will be further assembled into moulded brush block and will be used as a brush spring in a slip ring.” The brush springs placed in slip rings contribute to the transfer of electrical power from stationary to rotating members. You indicated that the brush springs in slip rings are primarily, but not exclusively, used in CCTV cameras. The brush springs are used to transfer power to the rotating camera’s motor, and to take signal and data from the camera. You also stated that the slip rings of this design may be used in any application that requires rotating/revolving while maintaining electrical/signal transmission. Common locations for the springs include video systems, robots, inspection equipment, manufacturing, process control equipment, medical equipment and packaging machines. In your letter, you proposed that the articles be classified as semi-manufactured parts containing over 2 percent of palladium in subheading 7110.29, Harmonized Tariff Schedule of the United States (HTSUS), which provides for platinum, unwrought or in semi-manufactured forms, palladium, other. However, the palladium springs do not fall within the list of goods identified under Section XIV, Chapter 71, Additional U.S. Note 1(b) for semi-manufactured products. Therefore, the springs are not a good of heading 7110, HTSUS. The applicable subheading for the palladium springs will be 7115.90.6000, HTSUS, which provides for other articles of precious metal or of metal clad with precious metal, other, other, other. The rate of duty will be 4 percent ad valorem. 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 Ann Taub at 646-733-3018. Sincerely, Gwenn Klein Kirschner Acting Director National Commodity Specialist Division