The tariff classification of an extension board from China

N327635 August 29, 2022 CLA-2-85:OT:RR:NC:N2:220 CATEGORY: Classification TARIFF NO.: 8537.10.9170; 9903.88.03 Mike Ferris Strader Ferris International 808 Commerce Park Dr. Ogdensburg, NY 13669 RE: The tariff classification of an extension board from China Dear Mr. Ferris: In your letter dated August 15, 2022, you requested a tariff classification ruling on behalf of your client, March Networks. The merchandise under consideration is identified as the Input/Output Extension Board (I/O Board), Model VMS-ALM-IO-16, which is described as having 16 alarm inputs and 16 relayed outputs. The I/O Board provides an electrical connection to 16 auxiliary devices, which you refer to as switches, similar to LEDs or sirens, and 16 alarm devices, such as panic buttons, smoke detectors, or temperature sensors. On the side of the I/O Board is an RJ45 socket for remote powering/network connection as well as a USB port for local control and power. In use, the I/O Board serves as a peripheral unit to a Command Recording Server and/or network video recording system where multiple devices are connected, and multiple devices are electrically controlled. The I/O Board has multiple DIN connectors for inputs and relayed outputs, and is stated to have a 200 V output. In your request, you suggest that the I/O Board is described as an accessory to video recording or reproducing apparatus and is classifiable under heading 8522, Harmonized Tariff Schedule of the United States (HTSUS). As the I/O Board is a machine that consists of two or more apparatus of heading 8536, where its principal function is to electrically connect and/or electrically control output devices, it is more specifically provided for elsewhere in the tariff. The applicable subheading for the Input/Output Extension Board, Model VMS-ALM-IO-16 will be 8537.10.9170, HTSUS, which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Other”. The general rate of duty will be 2.7 percent ad valorem. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8537.10.9170, 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 8537.10.9170, 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, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at the following addresses: https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions https://www.cbp.gov/trade/remedies/301-certain-products-china 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 Karl Moosbrugger at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division