The tariff classification of Wi-Fi Hub and Wi-Fi Bridge from China

N328617 October 28, 2022 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification TARIFF NO.: 8517.62.0090, 9903.88.15 Jennifer Diaz Diaz Trade Law 12700 Biscayne Blvd., Suite 401 North Miami, FL 33181 RE: The tariff classification of Wi-Fi Hub and Wi-Fi Bridge from China Dear Ms. Diaz: In your letter dated October 5, 2022, you requested a tariff classification ruling on a Wi-Fi Hub and Wi-Fi Bridge on behalf of your client, K-Rain Manufacturing Corporation. There are two items at issue with this request. The first item is identified as Wi-Fi Hub, Model# 3209. The subject item is an accessory for an irrigation controller, which is an optional part, allowing the user to control the irrigation system via the internet. The Wi-Fi Hub is designed to connect the irrigation controller to a home network by communicating between the irrigation controller and a home router. The Wi-Fi Hub communicates with the irrigation controller using the 433 MHz radio chip while the 2.4 GHz Wi-Fi chip communicates with the home router. Users are able to wirelessly connect their mobile devices such as smartphones or tablets to access the irrigation controller and use the functionality available within the controller. The second item is described as ProLC Wi-Fi Bridge, Model# 3100-BRIDGE, which is a USB dongle that connects to specific Wi-Fi ready irrigation controller’s USB port. This optional part is required to enable wireless connectivity with the irrigation controller. The USB dongle contains Bluetooth and 2.4 GHz Wi-Fi radio frequencies for communicating between the irrigation controller and the internet. This device allows the irrigation controller to be connected to a home network and provides access to the controller so that the user can control the functionality wirelessly using their mobile devices such as smartphones or tablets. The applicable subheading for the Wi-Fi Hub and Wi-Fi Bridge will be 8517.62.0090, Harmonized Tariff schedule of the United States (HTSUS), which provides for “Telephone sets, including smartphones and other telephones for cellular networks or for other wireless networks; other apparatus for the transmission or reception of voice, images or other data…: 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 8517.62.0090, HTSUS, unless specifically excluded, are subject to an additional 7.5 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 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