The tariff classification of a control module from Poland

N273606 March 28, 2016 CLA-2-85:OT:RR:NC:N4:120 CATEGORY: Classification TARIFF NO.: 8537.10.9060 Marilee Rice Import/Export Specialist Woodward, Inc. 1000 East Drake Road Fort Collins, CO 80525 RE: The tariff classification of a control module from Poland Dear Ms. Rice: In your letter dated February 29, 2016 you requested a tariff classification ruling. The item under consideration is referred to as the Large Engine Control Module (LECM) Series ECM555-80. The instant LECM controller consists of three distinct sub-modules which are fitted together for the purpose of managing and controlling the operation of reciprocating engines (gas, diesel, or dual fuel) in power generation, marine propulsion, and locomotive and industrial engine applications. The main module, which accommodates system and input/output functions, is constructed of a printed circuit board assembly (PCBA), three multi-pin connectors, an LED status display, and a cast aluminum enclosure. The second module, also referred to as the Electronic Ignition/Injection Driver Module, controls electronic ignition and injection functions and is constructed of a PCBA, two multi-pin connectors, and a cast aluminum enclosure. The third module, referred to as the Auxiliary Module, monitors and controls engine knock and is constructed of a PCBA, two multi-pin connectors, and a cast aluminum enclosure. All of the modules have the ability to work independently, or in unison with another module. The LECM is said to control all aspects of the engine’s operation. Some of the functions provided as examples include speed and load control, air/fuel ratio control, ignition and injector control, engine start and stop routines, and sensor monitoring. The LECM modules receive multiple sensor inputs and control the various elements of the engine’s operation based on the data received, which is processed using specialized proprietary control software. In addition, the LECM performs alarm monitoring data logging functions for troubleshooting, performance, and fault analysis. The applicable subheading for the Large Engine Control Module (LECM) Series ECM555-80 will be 8537.10.9060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Boards, panels, consoles, … and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity, … : For a voltage not exceeding 1,000 V: Other: Other: Programmable controllers.” The general rate of duty will be 2.7 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 Karl Moosbrugger at karl.moosbrugger@cbp.dhs.gov. Sincerely, Deborah C. Marinucci Acting Director National Commodity Specialist Division