The tariff classification of a control device from China

N251206 April 2, 2014 CLA-2-85:OT:RR:NC:N1:110 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 control device from China Dear Mr. Freston: In your letter dated February 26, 2014, you requested a tariff classification ruling. The submitted sample is being returned. The merchandise under consideration is referred to as the “Auxiliary Keypad”, Item number C4-KA. This device is a component of a home automation system. The device provides a 3-way control load using the existing in-wall 3-way wiring and wires directly to any compatible Control4 dimmer, switch, or fan-speed controller. The device is comprised of a printed circuit board assembly, two switches, a terminal block, resisters and electrical connecting wires. The C4-KA installs in a standard wall-box and connects and communicates with a compatible Control4 dimmer or switch using the traveler wire. The device sends a signal to a “master” device to which it is attached. It can be attached to a variety of different “master devices” some of which open and close a relay, and it may use a TRIAC or MOSEFET to adjust the light intensity level. It is stated that the C4-KA does not contain a potentiometer and without the automation controller this device would only be able to control the lighting load wired to it. 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, the C4-KA is more specifically provided for elsewhere in the tariff. The applicable subheading for the “Auxiliary Keypad”, Item number C4-KA 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 [email protected]. Sincerely, Gwenn Klein Kirschner Acting Director National Commodity Specialist Division