The tariff classification of an electronic tracking device from China

N255023 July 28, 2014 CLA-2-85:OT:RR:NC:N1:109  CATEGORY:  Classification TARIFF NO.: 8517.62.0050  Mr. Craig A. Lewis Hogan Lovells US LLP Columbia Square 555 Thirteenth Street, NW Washington, DC 20004 RE:  The tariff classification of an electronic tracking device from China Dear Mr. Lewis:In your letters dated July 3, 2014, you requested a tariff classification ruling on behalf of your client, Tile, Inc.  The merchandise under consideration is a wireless electronic tracking device that you refer to as “the Tile.” The Tile device consists of a 2.4 GHz semiconductor chip, a lithium battery, a Piezo sound element and other electronic components encased in a plastic housing which measures 36mm x 36mm x 4.6mm. You state in your letter that the Tile is a “system” (consisting of the Tile device, the Tile software application and the Tile “cloud” service) which is driven by the “cloud” service and a software application that allows an individual user, or a network of users, to locate small electronic devices via a “Bluetooth Low Energy” connection. In use the Tile would be attached to an item which the user wants to track. The Tile device transmits signals to and receives signals from a Bluetooth enabled device, such as a smartphone, that has been downloaded with the Tile software application (or “Tile app”). When any Tile-equipped device (smartphone) comes within range of the Tile, the Tile will transmit its unique identification number to that device. The smartphone will recognize the Tile (and the device to which it is attached) and using the location service capabilities of the phone provide a location for the Tile. Its transmission strength reaches up to approximately 150 feet. As an added feature, if the Tile should become lost, the user can report it as missing and alert the Tile cloud service to pick up and transmit the lost Tile’s signal when any other Tile user’s smartphone picks up the signal. Only the owner of the Tile will receive the report of the missing Tile’s location, making the entire Tile system a network of wireless receivers of location information.  The applicable subheading for the wireless electronic tracking device identified as “the Tile” 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 Steven Pollichino at [email protected]. Sincerely, Gwenn Klein Kirschner Director National Commodity Specialist Division