The tariff classification of a remote audience response kit from China
Issued January 24, 2020 by U.S. Customs and Border Protection.
Tariff classification
HTS codes: 8517.62.0090, 9903.88.15
Product description
The item concerned is referred to as a remote audience response kit. This kit consists of one base station (RF transceiver unit), 30 remote audience response devices (RF transceivers), and a USB cable. The remote audience response kit is used for training purposes. It allows groups of up to 30 people to be trained at the same time. The base station connects to a computer via the USB cable. The 30 RF remote response devices are individually assigned to each user. All 30 audience members watch the same training video on a single screen and answer questions with their remote response devices. Product specific software installed on the computer keeps track of exactly how each person answered each question, gives them a pass or fail score, and sends this information to an internet cloud-based management system for analysis and reporting. The kits do not include software; the software is distributed separately. The remote response devices wirelessly transmit user responses (answers) to and receive on/off signals from the base station. The base station wirelessly transmits/receives signals to and from the remote response devices, (can process up to 30 responses at once), and sends data to the connected computer via the USB cable (10 feet long). The remote audience response kit would be considered a functional unit as per Section XVI Note 4. All of the components work together to provide the user(s) with a transmission/reception functionality.
CBP rationale
The applicable subheading for the audience response kit will be 8517.62.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Telephone sets, including telephones for cellular networks or for other wireless networks; other apparatus for the 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), other than transmission or reception apparatus of heading 8443, 8525, 8527 or 8528; parts thereof: 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.
Full text
N308822 January 24, 2020 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification TARIFF NO.: 8517.62.0090, 9903.88.15 Insoo Eun Delta Trans Logistics Inc. 163 E. Compton Blvd Gardena, CA 92833 RE: The tariff classification of a remote audience response kit from China Dear Mr. Eun: In your letter dated January 8, 2020, you requested a tariff classification ruling. The item concerned is referred to as a remote audience response kit. This kit consists of one base station (RF transceiver unit), 30 remote audience response devices (RF transceivers), and a USB cable. The remote audience response kit is used for training purposes. It allows groups of up to 30 people to be trained at the same time. The base station connects to a computer via the USB cable. The 30 RF remote response devices are individually assigned to each user. All 30 audience members watch the same training video on a single screen and answer questions with their remote response devices. Product specific software installed on the computer keeps track of exactly how each person answered each question, gives them a pass or fail score, and sends this information to an internet cloud-based management system for analysis and reporting. The kits do not include software; the software is distributed separately. The remote response devices wirelessly transmit user responses (answers) to and receive on/off signals from the base station. The base station wirelessly transmits/receives signals to and from the remote response devices, (can process up to 30 responses at once), and sends data to the connected computer via the USB cable (10 feet long). The remote audience response kit would be considered a functional unit as per Section XVI Note 4. All of the components work together to provide the user(s) with a transmission/reception functionality. The applicable subheading for the audience response kit will be 8517.62.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Telephone sets, including telephones for cellular networks or for other wireless networks; other apparatus for the 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), other than transmission or reception apparatus of heading 8443, 8525, 8527 or 8528; parts thereof: 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. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8517.62.00, HTSUS, unless specifically excluded, are subject to an additional 15 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 8517.62.0090, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively. 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
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