The tariff classification of a plastic showerhead with a Bluetooth base from China

N325969 May 27, 2022 CLA-2-39:OT:RR:NC:N4:422 CATEGORY: Classification TARIFF NO.: 3924.90.5650 Ms. Susan Danks Susan Danks Tariff Consulting Pty Ltd. 17 Eisenhower Place Bonnet Bay Australia RE: The tariff classification of a plastic showerhead with a Bluetooth base from China Dear Ms. Danks: In your letter dated May 9, 2022, you requested a tariff classification ruling on behalf of your client, Hai Gethai Inc., for the smart showerhead. Schematic diagrams, drawings, parts, and cost breakdown sheets were also submitted for your request. The merchandise under consideration is referred to as a smart showerhead, model #’s HSBTHI1 and HSBTL01. This item is a plastic showerhead that features a Bluetooth base. The smart showerhead measures water consumption and water temperature and can send data by Bluetooth technology. Model # HSBTHI1 is a high flow shower and has a flow rate of 2.5 gallons per minute. Model #HSBTL01 is a low flow shower and has a flow rate of 1.8 gallons per minute. The smart showerhead comprises a plastic showerhead, a flexible polyvinyl chloride (PVC) hose, and a Bluetooth base, and clamp. The handle and face of the showerhead measure approximately 9.06 inches long by 4.45 inches wide by 2.32 inches in diameter. The hose measures approximately 59 inches long. The Bluetooth base and clamp measure approximately 4.69 inches long by 1.3 inches wide by 3.86 inches in diameter. You have indicated that the showerhead is available in the color accents of white, pink, blue, yellow, and red. You have also stated that the item has an add-on module for releasing a cosmetic product into the shower water as it disperses, which will be sold separately. The Bluetooth base and clamp is a single unit that connects the clamp to the water outlet and contains the Bluetooth turbine and, shower handset holder. The turbine is inside of the adaptor, which includes a temperature sensor. The hose is connected to the Bluetooth base, and the shower handset is connected to the hose. Once all three pieces are assembled and installed, the shower can be operated. As water passes through the integrated turbine, it forces the turbine to spin, which charges a lithium polymer battery. The battery powers the electronics PCB board, which measures the flow and temperature, sends data to the phone via Bluetooth, and powers the LED. The battery powers the board which can broadcast the signal. If the user wishes to customize the shower preferences or view the recorded shower usage, they must install the Hai mobile application on their cellular telephone and pair with the shower over Bluetooth. This item is a composite good within the meaning of General Rule of Interpretation (GRI) 3. The smart showerhead comprises a plastic showerhead, PVC hose, and Bluetooth base, and clamp. You have indicated that if the turbine were connected and still in the assembly and the Bluetooth was inoperable, the showerhead would still spray water, but the other features would not work. The plastic showerhead performs the primary function of dispersing water and being able to take a shower without the necessity to provide the temperature and water flow readings. We consider the measurement and temperature functions of the Bluetooth base secondary to the primary function of the showerhead. Therefore, it is the opinion of this office that the plastic showerhead provides this item with the essential character within the meaning of GRI 3(b). The applicable subheading for the smart showerhead, model #’s HSBTHI1 and HSBTL01 will be 3924.90.5650, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Tableware, kitchenware, other household articles and hygienic or toilet articles, of plastics: Other: Other: Other. The general rate of duty will be 3.4 percent ad valorem. 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 Dana L. Giammanco at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division