May 4 CBP Bulletin Proposes to Revoke, Modify Rulings on Circuit Board Assemblies, Keyboards
In the May 4 issue of the CBP Customs Bulletin (Vol. 50, No. 18) (here), CBP published notices that propose to revoke or modify rulings and similar treatment for printed circuit board switch assemblies and relabled computer keyboards.
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Comments on Proposals Due June 3
CBP said consideration will be given to any written comments received by June 3 before taking this action. In addition, any party who has received a ruling or decision on the merchandise that is subject to the proposed revocations or modifications, or any party involved with a substantially identical transaction, should advise CBP by the date that written comments on the proposed ruling are due. (An importer's failure to advise CBP of such rulings, decisions, or substantially identical transactions may raise issues of reasonable care on the part of the importer or its agents for importations subsequent to the effective date of the final decision in this notice.)
Proposals
CBP is proposing to revoke or modify the rulings below, and any rulings on these products that may exist but have not been specifically identified. CBP is also proposing to revoke any treatment it has previously accorded to substantially identical transactions.
Printed Circuit Board Assemblies
| Item: Printed circuit board assemblies from Canada. |
| Current: 8536.50.9031, 2.7%, (Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits...for a voltage not exceeding 1000 V: Other switches: Other: Other: Push-button: Rated at not over 5 A: Momentary contact.) |
| Proposed: 8537.10.90, 2.7%, (Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity, including those incorporating instruments or apparatus of chapter 90, and numerical control apparatus, other than switching apparatus of heading 8517: For a voltage not exceeding 1,000 V: Other) |
| Reason: CBP previously misinterpreted the meaning of the phrase “simple switch assembly,” it said. When properly read in concert with the text of heading 8537, "it is clear that the phrase 'simple switch assemblies' refers to two individual switches simply connected together to form a single unit with a double switch, and does not contemplate articles that contain multiples of articles classified in heading 8536 and that are mounted onto boards, panels or other bases," CBP said. |
| Proposed for revocation: NY N202228 (2012) |
| Proposed new ruling: HQ H250002 |
Relabled Keyboards
| Item: Computer keyboards and printed circuit board assemblies upon return to the United States from Mexico. |
| Current: Ineligible for duty free treatment under subheading 9802.00.5060 |
| Proposed: Keyboards with new part numbers and UPC labels was a repair or alteration eligible for duty free treatment under subheading 9802.00.50. |
| Reason: Based on past rulings, relabeling the keyboards with new part numbers and UPC labels was a repair or alteration eligible for duty free treatment under subheading 9802.00.50, as the identification purpose of the label advances the value or improves the condition of the keyboards, said CBP. |
| Proposed for modification: NY L83879 (2005) |
| Proposed new ruling: HQ H268757 |