The tariff classification of outdoor LED message signs from an undisclosed country of origin

N241753 May 28, 2013 CLA-2-85:OT:RR:NC:N1:112 CATEGORY: Classification TARIFF NO.: 8530.80.0000 Darrell G. Toth Vice President Quality Customs Broker, Inc. 615 N. Edgewood Ave. Wood Dale, IL 60191 RE: The tariff classification of outdoor LED message signs from an undisclosed country of origin Dear Mr. Toth: In your letter dated May 7, 2013, you requested a tariff classification ruling on behalf of your client, Adaptive Micro Systems LLC. The items concerned are referred to as outdoor LED message signs. There are four models/series concerned. Each model is intended to be used as an outdoor LED message sign, manufactured for roadside messaging applications. The first model is the AlphXpress 8600 DMS roadside messaging display. This LED display comes in 3 sizes: for the one line unit the measurements range from 61.2 inches to 229.2 inches in width, the height is a constant 34.75 inches, and the depth is a constant 14 inches. The pixels are arranged in columns ranging from 24 to 120, and in a constant 9 rows. For the two line unit the measurements range from 61.2 inches to 229.2 inches in width, the height is a constant 50.5 inches, and the depth is a constant 14 inches. The pixels are arranged in columns ranging from 24 to 120, and in a constant 18 rows. For the three line unit the measurements range from 61.2 inches to 229.2 inches in width, the height is a constant 66.25 inches, and the depth is a constant 14 inches. The pixels are arranged in columns ranging from 24 to 120, and in a constant 27 rows. The second model is the AlphXpress 8700 DMS roadside messaging display. This item comes in 4 sizes: for the one line unit the measurements range from 46.77 inches to 346.8 inches in width, the height is a constant 42.2 inches, and the depth is a constant 13.2 inches. The pixels are arranged in columns ranging from 18 to 126, and in a constant 9 rows. For the two line unit the measurements range from 159.6 inches to 346.8 inches in width, the height is a constant 65.6 inches, and the depth is a constant 13 inches. The pixels are arranged in columns ranging from 54 to 126, and in a constant 18 rows. For the three line unit the measurements range from 159.6 inches to 346.8 inches in width, the height is a constant 80 inches, and the depth is a constant 13.2 inches. The pixels are arranged in columns ranging from 54 to 126, and in a constant 27 rows. For the four line unit the measurements range from 159.6 inches to 346.8 inches in width, the height is a constant 112.4 inches, and the depth is a constant 13.2 inches. The pixels are arranged in columns ranging from 54 to 126, and in a constant 36 rows. The third model is the AlphXpress 9700 DMS roadside messaging display. It has 3 lines and the unit dimensions vary in width from 253.2 inches to 346.8 inches, the height is a constant 80 inches, and the depth is a constant 38.25 inches. The pixels are arranged in a constant 27 rows and the columns range from 90 to 126. The fourth model is the Full Color NTCIP LED DMS roadside messaging display. This item has many sizes ranging from 2 feet x 2 feet to 7feet x 30 feet. It incorporates RGB LED pixels. This item provides a combination of standard amber text with full color graphics. It has complete Ethernet connectivity to download files quickly. The Full Color NTCIP LED DMS instantly creates and broadcasts traffic instructions on arterial roadways, way-finding signs, and toll plaza signs. You have proposed classification of these displays under 8531.20.0040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for indicator panels incorporating liquid crystals devices or light emitting diodes. Based on the fact that these displays are used for signaling, safety and/or traffic control functions on roadways, it is the opinion of this office that these devices are more specifically provided for in heading 8530. The applicable subheading for the AlphXpress 8600 DMS, AlphXpress 8700 DMS, AlphXpress 9700 DMS, and the Full Color NTCIP DMS signs will be 8530.80.0000, “Electrical signaling, safety, or traffic control equipment…: Other equipment”. 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 the National Import Specialist at (646) 733-3008. Sincerely, Thomas J. Russo Director National Commodity Specialist Division