The tariff classification of media converters, SFP transceivers, POE Injectors and POE Splitters.

N301401 November 7, 2018 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification TARIFF NO.: 8504.40.8500, 8517.62.0090 Carl W. Mertz TP-Link USA Corp 145 South State College Blvd, Suite 400 Brea, CA 92821 RE: The tariff classification of media converters, SFP transceivers, POE Injectors and POE Splitters. Dear Mr. Mertz: In your letter dated October 1, 2018, you requested a tariff classification ruling. The first group of items concerned are TP-Link’s media converters (model #’s MC200CM, MC210CS, MC220L, MC100CM, MC110CS, MC111CS, and MC112CS). These small electronic devices are used to change a connection port and media type from one form to another. They would be used with SMB class routers and switches to change transmission media to a receivable form. The converters are used to convert a fiber optic connection/signal to an Ethernet connection/signal so the receiving device can make use of the data. The media converters are designed to convert between 10BASE-T/100BASE-T and 100BASE-FX, and between 1000BASE-T and 1000BASE-SX/1000BASE-LX. The media converters work at a full wire-speed forwarding rate. The second group of items concerned are the TL-SM311 series of mini GBIC modules (gigabit interface converters) (model #’s TL-SM311LS, TL-SM311LM). These devices are hot-pluggable adapters that slide into an SFP slot on a business switch or router to allow single-mode or multi-mode fiber optic cable to be attached. They adapt the physical connection port and the signal specifically, so that the router or switch can accept the fiber optical cable input. These are SFP (small form-factor pluggable) transceivers/converters. The third item concerned is a POE Injector (model # TL-POE150S). These electronic devices are used to provide power and data transmission over a single media cable (Ethernet cat5/cat5e/cat6). Injectors take a data only connection from a business router or switch and add power via an AC power adapter connected to standard U.S. outlet. Then they transmit both the power and the data over an Ethernet cable to a POE-enabled device, such as a camera, an access point or an IP phone. Injectors are only needed when the source device does not have a POE-enabled output. Injectors can be used by themselves or with a POE Splitter. The POE Injectors do not alter the data, they only add power to the transmission cable. The output is automatically determined based upon the necessary power requirements, up to a maximum of 15.4W, and they are 802.3af compliant. The fourth item concerned is a POE Splitter (model # TL-POE10R). These devices are the opposite of a POE Injector. They take a POE transmission and split the power from the data on the Ethernet cable. They are used when the end point device is a non-POE device. You can plug a male-end to male-end power cable into the splitter and the opposite end into the non-POE endpoint device to provide it power. The power output from a POE splitter can be switched between 5V, 9V or 12V depending on the power requirements of the endpoint non-POE device. As with the injector no changes are made in the data, it is only removing the power from the Ethernet cable, and they are 802.3af compliant. The applicable subheading for the media converters (model #’s MC200CM, MC210CS, MC220L, MC100CM, MC110CS, MC111CS, and MC112CS), and the TL-SM311 series mini GBIC module (model #’s TL-SM311LS/TL-SM311LM) will be 8517.62.0090, 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…: 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. The applicable subheading for the POE Injector (model # TL-POE150S), and the POE Splitter (model # TL-POE10R) will be 8504.40.8500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric transformers, static converters (for example rectifiers) and inductors; parts thereof: Static converters: For telecommunication apparatus.” The rate of duty will be Free. Effective July 6, 2018, the Office of the United States Trade Representative (USTR) imposed an additional tariff on certain products of China classified in the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), HTSUS. The USTR imposed additional tariffs, effective August 23, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(d), HTSUS. Subsequently, the USTR imposed further tariffs, effective September 24, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(f) and U.S. Note 20(g), HTSUS. For additional information, please see the relevant Federal Register notices dated June 20, 2018 (83 F.R. 28710), August 16, 2018 (83 F.R. 40823), and September 21, 2018 (83 F.R. 47974). Products of China that are provided for in subheading 9903.88.01, 9903.88.02, 9903.88.03, or 9903.88.04 and classified in one of the subheadings enumerated in U.S. Note 20(b), U.S. Note 20(d), U.S. Note 20(f) or U.S. Note 20(g) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees and charges that apply to such products, as well as to those imposed by the aforementioned Chapter 99 subheadings. Products of China classified under subheading 8504.40.85, HTSUS, unless specifically excluded, are subject to the additional 10 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8504.40.8500, HTSUS, listed above. The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading. 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