Dear Ms. Mobley:

In your letter dated March 20, 2001, you requested a ruling on tariff classification.

The sample you provided is item #191554, the "Ornamotion." It is a rotating motor used by attaching one end to the socket of a Christmas tree light and attaching an ornament to the other end. The motor is rated at 0.8 Watts and is synchronous. We assume that it is valued at less than $4.00. Section XX, Chapter 95, Note 1(m) states: "this chapter does not cover: . . . electric motors (heading 8501) . . .."

The applicable subheading for this product will be 8501.10.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for electric motors and generators, motors of an output not exceeding 37.5 W, of under 18.65 W, synchronous, valued not over $4 each. The general rate of duty will be 6.7 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 James Smyth at 212-637-7008.

Sincerely,

Robert B. Swierupski

Director

National Commodity

Specialist Division

In a memo to the CEO, thoroughly and completely explain what tariff we might have to pay on one of our newer products, an electric motor for Christmas tree lights, assuming that our products are treated the same way as the other Taiwanese product described in the letter.

Also in your memo, explain how our company might minimize the impact of any US tariffs on our products. What alternate business strategies might we pursue?