Tariff Classification Advance Ruling
PL65-12/24DC/12-24AC electric door strike insert

Applicant

Ms. Terri-Lynn Sharma
Rutherford Controls International Inc.
210 Shearson Crescent
Cambridge, ON
N1T 1J6

Date of issuance of ruling: December 17, 2015

This is in response to a request submitted on your behalf by Link+ Corp on the tariff classification of the PL65-12/24DC/12-24AC electric door strike insert manufactured by Salutica in Malaysia.

TRS Number: 271248
Classification Number: 8301.40.90.92
Effective Date: December 17, 2015

Product Description

The electric door strike insert (model PL65) is used in the manufacture of remote access devices by Rutherford Controls. This insert consists of several parts such as a multi-voltage single solenoid, locking cam and plug-in wire connectors, and is a major component of electric entry control assemblies similar to those used in apartment buildings, retail outlets and other facilities.

Analysis and Justification

The PL65 insert is used in the 6 Series Electric Strike assembly and when attached to the host power supply, acts as a controlled access point to the building. This insert is a complete electric strike with the exception of a faceplate, mounting hardware and trim-plate which will be supplied by Rutherford Controls depending upon the needs of their clients. The faceplates, mounting hardware and trim-plates do not change the function or the essential character of the electric strike. Rutherford Controls incorporates this strike insert with the faceplates, hardware and trim-plates and sells them as a complete package for their remote entry systems.

Heading 83.01 provides for locks (key, combination or electrically operated), of base metal. In the Canadian International Trade Tribunal (C.I.T.T) decision AP-95-100, the Tribunal classified the electric strikes in heading 83.01, more specifically under tariff item 8301.40.90 as locks rather than parts of locks.

Decision

Section 10 of the Customs Tariff directs that classification of imported goods shall be determined in accordance with the General Rules for the Interpretation of the Harmonized System. Section 11 of the Customs Tariff states that in interpreting the headings and subheadings, regard shall be had to the World Customs Organization's (WCO) Explanatory Notes to the Harmonized Commodity Description and Coding System.

General Interpretative Rule 1 (GIR 1) directs that titles of Sections, Chapters and sub-Chapters are provided for ease of reference only. For legal purposes, classification shall be determined according to the terms of the heading and any relative Section and Chapter Notes. Similarly, General Interpretative Rule 6 (GIR 6) directs that classification shall be determined according to the terms of those subheadings and any related Subheading Notes.

The PL65 electric door strike insert is classified under tariff item 8301.40.90.92 by virtue of GIR 1 and Canadian Rule 1.

Legislative/Administrative References

This ruling has been issued under paragraph 43.1(1)(c) of the Customs Act and will be honoured by the CBSA for future importations of the goods specified, provided the material facts and circumstances remain as originally presented; all conditions in the ruling have been met; the ruling has not been modified, revoked, revised, or cancelled; and the Customs Tariff legislation has not changed. Should there be a change in the material facts or circumstances pertaining to the goods, you must notify the CBSA as soon as possible. You may request that the advance ruling be modified or revoked as of the date of the change.

Importers should quote the advance ruling number at the time of importation in either the description field of the B3 entry document or on the Canada Customs Invoice. Exporters or producers should quote the advance ruling number on the Certificate of Origin or commercial invoice accompanying the goods.

Should you disagree with this advance ruling, you may file a dispute notice under subsection 60(2) of the Customs Act within 90 days of the date of issuance. Please see the procedures outlined in Appendix C of the CBSA's Memorandum D11-11-3, Advance Rulings for Tariff Classification.

This advance ruling is considered 'reason to believe' for the purposes of section 32.2 of the Customs Act and the CBSA's Administrative Monetary Penalty System, described in Memorandum D22-1-1.

All Memoranda referenced in this letter may be accessed on the CBSA website.

Consent to the Public Release of the Advance Ruling

As per your consent statement, we will release this advance ruling to the public, in both official languages, in accordance with the procedures described in Memorandum D11-11-3. The ruling will be published on the CBSA website in 30 days.

CBSA Contact

Mark Grant
Manager, Tariff Policy Unit 'B'
Trade Policy Division
Headquarters, Ottawa

File Number

C-2014-008718

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