The tariff classification of an (R) Emergency telephone dialer (Ronco® 911 + 3 Emergency Call System) from China

N015897 August 27, 2007 CLA-2-85:RR:NC:N1:109 CATEGORY: Classification TARIFF NO.: 8517.62.0050 Mr. Juan E. Jimenez, Jr. Proprietor, La Casa de los Ajos 713 La Paz Street San Juan, PR 00907 RE: The tariff classification of an (R) Emergency telephone dialer (Ronco® 911 + 3 Emergency Call System) from China Dear Mr. Jimenez: In your letter dated August 10, 2007 you requested a tariff classification ruling. The merchandise subject to this ruling is an (R) Emergency telephone dialer (Ronco® 911 + 3 Emergency Call System). Your letter states it is for the use of seniors who suffer a fall or medical emergency. The senior can call 911 emergency and 3 other phone numbers and request help. Upon connecting to 911 or one of the other 3 phone numbers a recorded message will commence, as in many instances the senior may not be able to speak. This item consists of a terminal (base unit), a telephone cable, a necklace pendant, a wrist strap pendant, a remote control, and a power adapter. The terminal has an auto dialer, a recorder, and a speaker. The telephone cable connects the terminal to the telephone wall jack. The necklace pendant, wrist strap pendant, and remote control have a panic button, which, when pressed, activates the terminal’s auto dialer and places a call to 911. Upon connection, a recorded message starts, in the event that the senior cannot speak. The connection also enables the senior and the 911 operator to carry-on a two way conversation through the two-way speaker within the terminal. Once the senior disconnects from 911, the other 3 phone numbers are dialed and the recorded message starts. The senior can also carry-on a two conversation via the two-way speaker in the terminal. The power adapter converts a wall outlet’s alternating current (AC) to direct current (DC) for use by the terminal. The (R) Emergency telephone dialer does not receive incoming telephone calls. As such, it is not considered a telephone, but rather transmission, conversion, and reception apparatus. The applicable subheading for the (R) Emergency telephone dialer (Ronco® 911 + 3 Emergency Call System) will be 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other”. The rate of duty will be free. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/. 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 Linda Hackett at 646-733-3015. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division