[TowerTalk] Fair-Rite and Tariffs

jimlux jimlux at earthlink.net
Mon Jul 15 21:27:52 EDT 2019


On 7/15/19 5:25 PM, Richard (Rick) Karlquist wrote:
> Are the toroids from Arrow marked "Made in Netherlands" or
> "Made in China".  If the latter, I don't understand why
> they are exempt from tariffs just because they were
> "laundered" through the Netherlands.  Can someone explain this?
> 

Oh wow..

Tariff stuff is mind bendingly complex.  There's all sorts of 
exceptions, exemptions, and weird rules.   It might be that you got the 
raw toroid from China, but then did some "manufacturing" on it to 
transform it to another category (a "painted toroid" or a "ferrite 
toroids, plastic covered, on car"

And, of course, it's possible that the toroid was actually made in the 
Netherlands (Philips, or whatever they are called now, is a Dutch 
company), but the powdered metal came from China.

ALso, how it's described.. is it a powdered metal toroid, or an EMI filter?


Short answer, it is harder to make sense of tariff rules and 
classifications than it is to make sense of export control rules, and 
those are none-too-easy.


I tried to find the tariff description, and helpfully, one of the 
Chinese suppliers has the Harmonized System (HS) code for their toroids, 
which got me started down a horrible rabbit hole.


HS code 8504.90

85 is electrical machinery
8504.90. is "parts for Electric Transformers, static Converters, inductors"

8504.90.95.10 is "for transformers" vs
8504.90.95.45 is "for Other, and not laminations, stacked cores, nor 
wound cores"


you can read a sample determination opinion here:
https://docs.google.com/viewerng/viewer?url=http://s3.amazonaws.com/flexport-web/production/assets/D88010.DOC?1464044424


On the other hand if it's described as HS 8504.90.75.00  Parts: Other, 
Other you're going to pay a tariff, because it's not 8504.90.65.00 of 
goods of subheading 8504.40 or 8504.50 for telecommunications apparatus, 
whcih has no tariff.

Because, after all, Electronic parts, "For power supplies for automatic 
data processing machines or units thereof of heading 8471; power 
supplies for goods of subheading 8443.31 or 8443.32; power supplies for 
monitors of subheading 8528.41 or 8528.51 or projectors of subheading 
8528.61; for telecommunication apparatus."  are tariff free

Clearly the manufacturers and importers of projectors 8528.61 have 
managed to get some special treatment.
No doubt as a result of:
"Ruling Request; U.S. International Trade Commission; Limited Exclusion 
Order; Investigation No. 337-TA-1001, Certain Digital Video Receivers 
and Hardware and Software Components Thereof" on 3/5/2018



I found another list of "new tariff commodities"
8504.90.41	Parts of power supplies (other than printed circuit 
assemblies) for automatic data processing machines or units thereof of 
heading 8471
8504.90.65	Printed circuit assemblies of the goods of subheading 8504.40 
or 8504.50 for telecommunication apparatus
8504.90.75	Printed circuit assemblies of electrical transformers, static 
converters and inductors, nesoi
8504.90.96	Parts (other than printed circuit assemblies) of electrical 
transformers, static converters and inductors



by the way, you'll see the abbreviation/acronym nesoi ->  "Not Elsewhere 
Specified or Included."  - the catchall


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