The tariff classification of the Automation HAT from Great Britain

N289376 August 31, 2017 CLA-2-85:OT:RR:NC:N2:120 CATEGORY: Classification TARIFF NO.: 8537.10.9160 Cathy Spencer Freight Expediters 6920 Engle Rd. Suite II Middleburg Heights, OH 44130 RE: The tariff classification of the Automation HAT from Great Britain Dear Ms. Spencer: In your letter dated August 18, 2017 you requested a tariff classification ruling on behalf of your client, International Products Sourcing Group. The merchandise under consideration is identified as the Automation HAT and is said to be an accessory component used exclusively with the Raspberry Pi. Accessories for the Rasberry Pi are commonly referred to as a “HAT” or a “pHAT.” These acronyms represent the method of affixing the devices to the Raspberry Pi and simply stand for the term “Hardware Attached on Top.” The term “pHAT” merely identifies a smaller version of the HAT. Generally, HATs and pHATs are printed circuit board assemblies that perform a variety of specific functions and incorporate a mounted EEPROM which identifies the device to the Raspberry Pi. The subject Automation HAT is described as a small printed circuit board assembly having three contact relays, two terminal boards, numerous status LEDs, and control circuitry and is intended to be mounted to a Raspberry PI for the purpose of controlling electrical devices such as pumps, lights, motors, or other light automation tasks through the use of its analog and digital outputs. The Automation HAT has numerous sensor and communication inputs that it uses for the electrical control of its attached machines. With the requisite programming, the user can provide automatic control operations based on sensor inputs, such as timing or turning devices on or off. We would note that the Raspberry Pi has been classified previously by this office in NY N285104 as an automatic data processing (ADP) machine. In N285104, we found that the conditions set forth in Chapter 84 Note 5, Harmonized Tariff Schedule of the United States (HTSUS), which governs the classification of ADP machines and their units, were satisfied and the Raspberry Pi was classifiable in subheading 8471.50, HTSUS. However, although the subject Automation HAT is a dedicated accessory to the Raspberry Pi, its primary function is to electrically control external machines and is performing a function that is not considered data processing. In your request you have suggested the Automation HAT is correctly classified under subheading 8537.10.9160, Harmonized Tariff Schedule of the United States (HTSUS), which provides for programmable controllers. We agree with the suggested classification as the Automation HAT is a digital apparatus which uses programmable memory to store program instructions for the purpose of controlling machines through digital or analog inputs and outputs. The applicable subheading for the Automation HAT will be 8537.10.9160, HTSUS, which provides for “Boards, panels, consoles, … and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity, … : For a voltage not exceeding 1,000 V: Other: Other: Programmable controllers.” The 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 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 Karl Moosbrugger at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division