The tariff classification of tracking devices from Canada

N108330 June 22, 2010 CLA-2-85:OT:RR:NC:N1:108 CATEGORY: Classification TARIFF NO.: 8526.91.0040 Mr. Karl F. Krueger Radix Group Int’l dba DHL Global Forwarding 2660 20th Street Port Huron, MI 48060 RE: The tariff classification of tracking devices from Canada Dear Mr. Krueger: In your letter dated June 3, 2010, on behalf of Wireless Matrix, you requested a tariff classification ruling. The merchandise under consideration is the Wireless Matrix Reporter 101 and the Wireless Matrix Reporter 112. These small radio navigation aid devices are designed to track mobile assets such as trucks. Both Matrix Reporters are integrated with Wireless Matrix’s FleetOutlook® solution for mobile resource management, and are compatible with wireless Matrix’s TechConnect® solution for messaging and job dispatch. In addition, these tracking devices, which are equipped with USB device ports for interface with USB-equipped devices, are small enough to be mounted on the windshield inside a vehicle or out-of-sight under the dashboard. The Reporter 101, which consists of a sensitive GPS receiver and a General Packet Radio Service (GPRS) transceiver, receives real-time global positioning system (GPS) location information and transmits this data over a GPRS cellular network. The Reporter 112 integrates a 1xRTT transceiver with a sensitive GPS receiver for tracking purposes. This tracking device receives GPS information and transmits this data over a code division multiple access (CDMA) 1xRTT cellular network. The Reporter 101 and the Reporter 112 are both multifunction machines and as such are classified in accordance with Legal Note 3 to Section XVI, HTSUS. It is the opinion of this office that the principal function of these devices is being performed by the radio navigational aid (GPS) function. The applicable subheading for these tracking devices will be 8526.91.0040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Radar apparatus, radio navigational aid apparatus and radio remote control apparatus: Other: Radio navigational aid 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 Lisa Cariello at (646) 733-3014. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division