Tariff Classification Advance Ruling
Lead Acid Accumulator Batteries, Product Numbers 88000002, 88000007 and 88000021


Ms. Harriet Bunce
Tyco Safety Products Canada Ltd.
3301 Langstaff Road
Concord, ON  L4K 4L2

Date of issuance of ruling:

This is in response to your request for an advance ruling on the tariff classification of Lead Acid Accumulator Batteries, Product Numbers 88000002, 88000007 and 88000021. These products are exported from KJK International LLC, Cedar Knolls, NJ, U.S.A.

TRS Number: 275056
Classification Number: 8507.20.90.20
Effective Date:

Product Description

These products are 12-volt lead acid accumulator batteries that are incorporated as the power source into control panels for combined fire and burglary detector alarm systems manufactured in Canada.

Analysis and Justification

You have requested consideration under classification 8507.20.10.00 of the Customs Tariff for these products. Batteries are named in heading 85.07 and are not excluded by any Legal or Explanatory Notes. These batteries provide power to the control panel of combined fire and burglary alarm systems. Batteries for fire alarm systems are classified under 8507.20.10. Batteries for burglar alarm systems are classified under 8507.20.90, so there are two classifications that deserve equal consideration. Neither the fire alarm component nor the burglary alarm component takes precedence over the other. As two classifications merit equal consideration, essential character cannot be determined and the goods must be classified using General Interpretative Rule 3(c) which states they shall be classified under the heading which occurs last in numerical order among those which equally merit consideration.


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.

These 12-volt Lead Acid Accumulator Batteries, Product # 88000002, 88000007, and 88000021 for use in combined fire and burglary alarm systems are classified under 8507.20.90.20 of the Customs Tariff in accordance with General Interpretative Rules 1, 3(c) and 6.

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 as described in Memorandum D22-1-1, Administrative Monetary Penalty System.

All D-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.

CBSA Contact

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

File Number


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