The tariff classification of an interactive smart mirror from Mexico

N302145 December 21, 2018 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification TARIFF NO.: 8517.62.0090 Sandra L. Weston Capin-Vybony LLC 949 W. Bell Rd. Nogales, AZ 85621 RE: The tariff classification of an interactive smart mirror from Mexico Dear Ms. Weston: In your letter dated November 19, 2018, you requested a tariff classification ruling on behalf of your client, International Contract Assembly Group LLC (ICAG). The item concerned is referred to as the Interactive Smart Mirror. It consists of a mirrored 40" LCD panel display, a customized single board computer running a modified version of Android Lollipop, a video and audio processor, a Wi-Fi antenna, a memory module, 2 speakers, a dual-band microphone, a camera, and it uses a MDMS protocol to interface with an iOS app that controls it. The primary function of this item is to provide individuals with remote access to interactive exercise programs that are monitored at a home base. The Interactive Smart Mirror also allows for a one-on-one session with a trainer based in New York and/or participation in remote group exercise classes. It is used for aerobics, calisthenics, etc. The Interactive Smart Mirror displays correct positions for various exercises and will let the user know when they are not to form. The unit will also display data from the various activities it supports while the user is performing them. Data is stored at a central Cloud based location. This provides the user with a running history of their activities. The Interactive Smart Mirror connects to a smartphone via a smart phone application (Apple/Android). The Interactive Smart Mirror application monitors the smartphone's built-in services and shares those services with the unit. Once the Interactive Smart Mirror is paired with and connected to a smartphone, it may utilize services provided by the smartphone (e.g. Geo-location, messaging, hands-free conversations, notifications, alerts, etc.). In addition, the Interactive Smart Mirror utilizes the smartphone to send and receive data from the internet (e.g. downloads exercise, statistics, and files). The Interactive Smart Mirror enables the user to receive incoming email alerts and text messages via the tethered smart phone. The Interactive Smart Mirror does not incorporate a cellular modem. In order to connect to the internet, it requires either a paired mobile phone or an available Wi-Fi hot spot. The user controls the Interactive Smart Mirror using their smart phone or tablet. The applicable subheading for the Interactive Smart Mirror will be 8517.62.0090, 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. 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