The tariff classification of a robotic vacuum cleaner from China

N322828 December 6, 2021 CLA-2-85:OT:RR:NC:N4:410 CATEGORY: Classification TARIFF NO.: 8508.11.0000; 9903.88.03 Mr. Robert Glover Coppersmith Global Logistics 525 S Douglas St. El Segundo, CA 90245 RE: The tariff classification of a robotic vacuum cleaner from China Dear Mr. Glover: In your letter dated November 16, 2021, you requested a tariff classification ruling on behalf of Ecovacs Robotics Inc. Pictures and product specifications were submitted with your request. The product is identified as the Robotic Floor Washing Machine, Model DLN11 (N8 PRO) (the “Vacuum Cleaner”). Based on the information and pictures that you have provided, the Vacuum Cleaner is in a round shape measuring 427mm in length, 162mm in width and 488mm in height and with self-contained motor. It is rated 100-240VAC and 40W with the dust bin capacity of 0.42 L. The Vacuum Cleaner is designed to use physical detection 3D technology to identify obstacles precisely and avoid instantly in vacuuming and mapping the floor. The visual recognition navigation and mapping technology maps the floor and recognizes the environmental information without collisions. The side brushes rotate continuously and sweep the dust into the suction port from both sides of machine, and the mopping pad attached to the back of the machine cleans the floor to complete the whole process of floor cleaning. Model DLN11 (N8 PRO) is packaged with a rechargeable battery, docking station, side brushes, mopping pad plate, washing mopping pad and disposable mopping pads. The applicable subheading for the Robotic Floor Washing Machine, Model DLN11 (N8 PRO), will be 8508.11.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Vacuum cleaners, parts thereof: With a self-contained electric motor: Of a power not exceeding 1,500 W and having a dust bag or other receptacle capacity not exceeding 20 l”. The rate of duty will be Free. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8508.11.0000, HTSUS, unless specifically excluded, are subject to an additional 25 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 8508.11.0000, 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. 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 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 Michael Chen at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division