The tariff classification of a programmable robot from China

N297741 June 29, 2018 CLA-2-85:OT:RR:NC:N2:220 CATEGORY: Classification TARIFF NO.: 8543.70.9960 Cecelia Rothrock Crane Worldwide Logistics LLC 1500 Ranking Road Houston, TX 77073 RE: The tariff classification of a programmable robot from China Dear Ms. Rothrock: In your letter dated June 8, 2018 you requested a tariff classification ruling on behalf of your client, Misty Robotics. The merchandise under consideration is identified as the Misty II Personal Robot (Misty II) which is described as a programmable robot that measures approximately 35 cm high by 20 cm wide and is fitted with electric motors for movement. The Misty II features an LCD display, a 4K camera, 3X far-field microphone array, internal memory, a rechargeable battery, speakers, and Bluetooth/Wi-Fi capabilities. Integrated into the Misty II are a number of sensors that provide obstacle avoidance, bump sensors, and 6X capacitive touch. It is powered by Qualcomm Snapdragon processors and runs on Windows IoT Core or Android 7 operating systems. Included in the packaging is the robot, a self-charging dock, a power adapter, a quick start guide, and a desk stand. In use, the Misty II is programmed to perform various functions and tasks that you refer to as skills. The Misty II is sold with existing skills such as navigating within a map, face detection, room mapping, path planning, object and voice recognition, and adaptive personality. However the unit’s stated purpose is for software developers to write new code for additional skills that teaches the robot to integrate functions such as sight, speaking, hearing, moving, and recognition of objects or people. The applicable subheading for the Misty II Personal Robot will be 8543.70.9960, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; Other machines and apparatus; …Other.” The rate of duty will be 2.6 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