The tariff classification of a home automation controller from China

N225399 July 23, 2012 CLA-2-85:OT:RR:NC:N1:112 CATEGORY: Classification TARIFF NO.: 8543.70.9650 Mr. David L. Freston Traffic Manager Control4 11734 Election Road Draper, UT 84020 RE: The tariff classification of a home automation controller from China Dear Mr. Freston: In your letter received by this office on July 9, 2012, you requested a tariff classification ruling. The item concerned is referred to as Control4’s “Home Controller” model # C4- HC300C-E-B. This electronic device is a total home control interface. It is a control processor used to automate the operation of electronic systems/devices through out the home. The back of the unit incorporates a variety of connection ports, i.e. a power plug port, video out jacks, audio out jacks, audio in jacks, video sense In-Out jacks, Ethernet port, USB port, contact block, relay block, serial port, IR out, and an identification button. This controller provides options for controlling lights, home theater, distributed audio systems, and other devices which are controlled using various protocols/interfaces such as, infra red (IR), serial RS232, contact, relay, Ethernet, Wifi and Zigbee RF 2.4Ghz. It provides extensive media management services for audio sources, such as CDs and DVDs stored in connected devices. It allows you to use an external storage device with USB support for media storage, and it has multi-zone audio capabilities that can send music to rooms throughout a home. Once the controller and other components are installed and configured (using Control4 Composer software), the user can control the system using an interface device, i.e. the SR-250 remote control. You have proposed classification under heading 8537, HTSUS, which provides for boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for the electric control or distribution of electricity. This device is not simply controlling or distributing electrical current, it’s performing processing functions that are outside the scope of heading 8537. As such heading 8537 is inapplicable. The applicable subheading for the “Home Controller” model # C4- HC300C-E-B will be 8543.70.9650, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Other machines and apparatus: Other: Other: Other: Other.” The general rate of duty will be 2.6%. 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 Steven Pollichino at (646) 733-3008. Sincerely, Thomas J. Russo Director National Commodity Specialist Division