The tariff classification of an Entertainment and Automation Controller from China

N273128 March 18, 2016 CLA-2-85:OT:RR:NC:N4:112 CATEGORY: Classification TARIFF NO.: 8543.70.9650 David Freston Control4 3612 West 1820 South Salt Lake City, UT 84104 RE: The tariff classification of an Entertainment and Automation Controller from China Dear Mr. Freston: In your letter dated February 12, 2016, you requested a tariff classification ruling. The iem concerned is referred to as the Control4 EA-5 Controller. This electronic device is a processing unit that is used to control and manage entertainment components as well as other Control4 home automation devicses. The Control4 EA-5 Entertainment and Automation Controller is designed to deliver the ultimate smart home experience. It features high-quality audio and processing power to coordinate hundreds of smart devices. The EA-5 can automate sophisticated home theaters, complex interior and exterior lighting scenes, vital security and communications systems, and climate controls for multiple zones. The EA-5 features five independent audio outputs—two digital coaxial, two RCA stereo analog, and one HDMI.. A built-in music server delivers immersive, multi-stream, high-resolution audio. The EA-5 also features secure, wireless ZigBee communication. It incorporates a variesty of input and output ports including IR, serial, contacts and relays, and IP control enabled connections to smart home devices such as thermostats, door locks, doorbells, cameras, security panels, sensors, lighting, shades, garage door controllers, irrigation systems, and much more. You suggest the classification of the EA-5 Controller should be 8471.50.0150, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Automatic data processing machines and units thereof… Processing units other than those of subheading 8471.41 or 8471.49, whether or not containing in the same housing one or two of the following types of unit: storage units, input units, output units: Other.” We disagree as it does not meet all the requirements of Note 5A to Chapter 84, HTSUS. Based on the information provided, the EA-5 Controller is not freely programmable by the end user and is limited in its capabilities since it is not able to do its own processing. In this regard, these devices do not meet all the requirements of an ADP machine of heading 8471, HTSUS, and classification in heading 8471, HTSUS, is precluded. The applicable subheading for the Control4 EA-5 Controller 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 [email protected]. Sincerely, Deborah C. Marinucci Acting Director National Commodity Specialist Division