The tariff classification of a network gateway device from an unspecified country of origin

N293001 January 16, 2018 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification TARIFF NO.: 8517.62.0050 Mr. John M. Peterson Neville Peterson LLP - Counsellors at Law One Exchange Plaza 55 Broadway, Suite 2602 New York, NY 10006 RE: The tariff classification of a network gateway device from an unspecified country of origin Dear Mr. Peterson: In your letter dated December 10, 2017, you requested a tariff classification ruling on behalf of your client, Chamberlain Group, Inc. The item concerned is referred to as the LiftMaster 828. It is an internet gateway device used with Chamberlain's proprietary "MyQ" technology and software to allow users to access and control devices over the internet. In its condition as imported, the device is a small module (measuring approximately 4 inches wide by 2.5 inches high and 1 inch thick) featuring data processing boards and an internal antenna. It is designed to be connected to a broadband router, which in turn is connected to a broadband source. The gateway, when activated, establishes a peer-to-peer network with certain linked household appliances using a 50 band Frequency Hopping Spread Spectrum (FHSS) operating in the 902-928 gHz frequency range. It utilizes a proprietary semiconductor chip assembly which is designed to handle communications in a low power, low frequency network. The gateway can be used to enable internet-based control of a variety of Chamberlain devices, including Garage Door Openers, Logic 5.0 Commercial Garage Door Openers, Gate Operators and Light Controls. In order to be installed in a home, the Liftmaster 828 internet gateway must be connected by an Ethernet cable to a wireless router, which in turn, must be connected to a broadband internet service. A user must first register his or her LiftMaster 828 gateway by going to a Liftmaster website and creating a MyQ account. Once an account is created, the user can then install various Chamberlain appliances to the peer-to-peer network, establishing a two-way data communication stream between the internet gateway and the connected device. Once the network is established, a user can, from a desktop, laptop or smart phone, access the network and obtain information concerning the status of any device thereon. For example, a user can query whether his garage door is "open" or "closed". If the user has accidentally left his garage door open, he can access the device on the Internet, using the MyQ network software, and direct that the door close. The applicable subheading for the LiftMaster 828 gateway will be 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Telephone sets…; other apparatus for the transmission or reception of voice, images or other data…: 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 general 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