The tariff classification of a programmable control device from China

N250693 March 19, 2014 CLA-2-85:OT:RR:NC:N3:110 CATEGORY: Classification TARIFF NO.: 8537.10.9060 Mr. David Freston Control4 11734 South Election Road, Ste. 200 Salt Lake City, UT 84020 RE: The tariff classification of a programmable control device from China Dear Mr. Freston: In your letter dated February 18, 2014, you requested a tariff classification ruling. The submitted sample is being returned. The merchandise under consideration is referred to as the “ELV Wireless Dimmer”, part number C4-TDIM1-Z. This device is a component of a home automation system. It is a programmable device that receives its signal from the Control4 controller (the “brain” of the Control4 system) via RF communication to adjust the intensity level of the attached lighting devices. The device is comprised of a printed circuit board assembly, an on/off switch, two metal–oxide–semiconductor field-effect transistor (MOSFET) switches, a relay, sixteen-pin connector and five electrical wires. The buttons on this device can be programmed to control the local light devices attached to it. It can also be programmed to communicate with the controller in the Control4 system to perform other tasks such as, controlling other lights that are attached to other control devices. The C4-TDIM1-Z can also control the attached lighting devices via phase-cut dimming over the line-voltage wires. It is stated that this device does not contain a potentiometer. The device is rated 120V. In your request you suggested classification in subheading 8543.90.8880, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Parts: Other: Other: Other.”. However, this programmable dimmer is more specifically provided for elsewhere in the tariff. The applicable subheading for the “ELV Wireless Dimmer”, part number C4-TDIM1-Z will be 8537.10.9060, (HTSUS), which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Programmable controllers.” The general rate of duty will be 2.7 percent ad valorem. 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 Hope Abada at (646) 733-3016. Sincerely, Gwenn Klein Kirschner Acting Director National Commodity Specialist Division