The tariff classification of a Network Interface Device from an unspecified country of origin

N281245 December 14, 2016 CLA-2-85:OT:RR:NC:N4:109 CATEGORY: Classification TARIFF NO.: 8517.62.0050 Lawrence M. Friedman Barnes, Richardson & Colburn, LLP 100 William Street, Suite 305 New York, NY 10038 RE: The tariff classification of a Network Interface Device from an unspecified country of origin Dear Mr. Friedman: In your letter dated November 10, 2016, you requested a tariff classification ruling on behalf of your client, Electrolux Home Products, Inc. The item concerned is a network interface unit (“NIU”). Presently, this network device is intended to be installed in home washing machines and dryers. The NIU may, without modification to the hardware, find application in other Electrolux appliances as well. The Electrolux NIU is used to provide home laundry equipment with the connectivity necessary for the appliances to form part of the Internet of Things (“IoT”). The device is an electronic module that enables Wi-Fi connectivity between the appliance and a remote network gateway, such as a wireless router. Once connected to the router, the NIU can communicate via standard 802.11b/g/n data protocols to the Internet to provide information to users and to accept commands from users. The user interface is an application installed on a mobile device such as a tablet or phone, or potentially through a computer using a web interface. The NIU transfers user commands to the electronic user interface in the appliance, which then activates the appropriate controls. The primary components of the NIU are DDR2-800 memory modules (totaling 64 MB of on-board RAM memory), 128 Mbit flash modules (totaling 32 MB), a Qualcomm QCA4531 System-on-Chip access point and a four-layer printed circuit board. The applicable subheading for the Network Interface Device will be 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Telephone sets, including telephones for cellular networks or for other wireless networks; other apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network…: Other apparatus for transmission or reception of voice, images or other data…: 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 https://hts.usitc.gov/current. 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, Steven A. Mack Director National Commodity Specialist Division