The tariff classification of fleet tracking devices from China and/or Mexico

N300201 September 11, 2018 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification TARIFF NO.: 8517.62.0050 Brenda A. Jacobs Sidley Austin LLP 1501 K Street, N.W. Washington, D.C. 20005 RE: The tariff classification of fleet tracking devices from China and/or Mexico Dear Ms. Jacobs: In your letter dated August 14, 2018, you requested a tariff classification ruling on behalf of your client, Flex Ltd. The items concerned are the Flex OBD-II asset tracker, the TT600 solar powered asset tracker with Cat-M, and the TT603 solar powered asset tracker with Cat-M. The primary purpose of these devices is to collect, record and transmit/receive data essential to asset management (assets such as vehicles, trailers or containers). The information gathered enables fleet owners to identify key facts essential to analyzing and effectively managing fleets. The Flex OBD-11 asset tracker has access to a power source from the vehicle it is monitoring while the solar powered asset trackers are intended for trailers, containers, construction equipment, pumps, and other large unpowered assets. Both the Flex OBD-II and the solar powered devices have global cellular connectivity. These devices receive and transmit data between an asset, such as a truck or a container, and a remote/external server connected to the internet, transmitting that data over a global wireless network. These devices collect and generate information related to data points such as fuel consumption, system health, driver behavior, speed, tire pressure, mileage traveled, and total stop time in non-depot locations. Fleet owners can use the collected data to identify what percentage of vehicles or other assets (such as trailers or containers) are in use in a particular month and thereby make capacity decisions. The applicable subheading for the Flex OBD-II asset tracker, the TT600 solar powered asset tracker with Cat-M, and the TT603 solar powered asset tracker with Cat-M 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 the 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