The tariff classification of telecommunication devices from China

N304611 June 21, 2019 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification TARIFF NO.: 8517.12.0080, 8517.18.0010 John D. Van Dyke Avaya 350 Mt Kemble Ave Room 2C111 PO Box 1934 Morristown, NJ 07960 RE: The tariff classification of telecommunication devices from China Dear Mr. Van Dyke: In your letter dated June 3, 2019, you requested a tariff classification ruling. The items concerned are referred to as the Avaya Vantage K155, Avaya Vantage K165 and Avaya Vantage K175. These devices are unified communication devices used in business/office setting communications. They take the place of a traditional desktop telephone. The K155 is an innovative desktop communication device designed for users that prefer a traditional dial-pad functionality. This desktop telecommunication device incorporates a 5 inch 720x1280 capacitive touch display, built-in Wi-Fi and hotspot, Bluetooth 4.2 LE, one C-Type USB port, 16 GB flash memory, caller ID with name, number and photo, downloadable ringtones and wallpapers, contact integration, corded handset, high-quality hands-free speaker, and camera. The K165 and K175 are fully customizable desktop communication devices. They feature open architecture and are designed to deliver multidimensional communication with unique video capabilities. They employ a simplified user interface on a large touch-screen display and eliminate unnatural workflows or pauses during communication. The difference between the two models is that the K175 features an integrated camera, and the K165 does not incorporate a camera. These desktop communication devices incorporate an 8 inch 720x1280 capacitive touch color display, built-in Wi-Fi and hotspot, Bluetooth 4.2 LE, one C-Type USB port, 16 GB flash memory, caller ID with name, number and photo, downloadable ringtones and wallpapers, contact integration, cordless Bluetooth handset with inductive charging, corded handset, high-quality hands-free speaker and a camera (in the K175 model only). The applicable subheading for the Avaya Vantage K165 will be 8517.12.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Telephone sets, including telephones for cellular networks or for other wireless networks…: Telephone sets, including telephones for cellular networks or for other wireless networks: Telephones for cellular networks or for other wireless networks: Other.” The rate of duty will be Free. The applicable subheading for the Avaya Vantage K155 and Avaya Vantage K175 will be 8517.18.0010, (HTSUS), which provides for “Telephone sets, including telephones for cellular networks or for other wireless networks…: Telephone sets, including telephones for cellular networks or for other wireless networks: Other: Videophones.” The 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