The tariff classification of a cobra tag from China

N176296 August 19, 2011 CLA-2-85:OT:RR:NC:N1:109 CATEGORY: Classification TARIFF NO.: 8517.62.0050 Mr. Daniel Schiff Vice President, Operations Cobra Electronics Corporation 6500 West Cortland Street Chicago IL 60707 RE: The tariff classification of a cobra tag from China Dear Mr. Schiff: In your letter dated July 21, 2011, you requested a tariff classification ruling. The merchandise under consideration is a cobra tag. Within your submission you refer to it as product BT 225. The device uses a battery powered Bluetooth RF module to continually transmit data to and receive data from a Bluetooth enabled device, such as a mobile telephone. It will be imported with a battery and USB charging cable. The cobra tag sensor can be attached to a key ring, purse, computer bag, or any other item the user wants to protect from loss because the sensor is capable of communicating with a cell phone’s free application (app) to notify/remind the user if they leave their cell phone or other valuables, i.e., key ring, purse, computer bag, etc., behind. The cobra tag is also a 2-way finder. If the user cannot locate their Smartphone, they can tap the button on the cobra tag and a ring tone will sound to their Smartphone so that the user can locate it. If the user is looking for other cobra tag protected items, they can use the Smartphone’s application to make the cobra tag ring and any item that it is attached to can be located by detecting where the ring tone is coming from. The BT 225 works with Android™ and Blackberry® Smartphones.
? The cobra tag located directly above will be imported separately from the other displayed items. The applicable subheading for the cobra tag will be 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network): 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 M. Hackett at (646) 733-3015. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division