The tariff classification of RFID measuring devices from Austria

N359501
March 31, 2026
CLA-2-90:OT:RR:NC:N1:105
CATEGORY: Classification
TARIFF NO.: 9031.80.8085
Martina Parz Cisc Semiconductor GmbH Lakeside 7 Klagenfurt 9020 Austria RE: The tariff classification of RFID measuring devices from Austria Dear Ms. Parz: In your letter dated March 6, 2026, you requested a tariff classification ruling. Descriptive literature was provided for our review. The first item under consideration is described as the CISC RFID Xplorer, which is a compact, high-precision Ultra High Frequency (UHF) Radio-frequency identification (RFID) test and measurement instrument. It is used for performance and conformance testing of UHF RFID readers and tags, operating from approximately 700 MHz to 1.2 GHz. The device measures tag sensitivity, communication range, backscatter power, tag radiation patterns, and conformance parameters, offering modes for tag performance, reader testing, and RF signal analysis. A real-time sniffer records and decodes reader–tag communication, including protocol and spectrum analysis. This product is not a communication device; instead, it generates controlled RF test signals and evaluates RFID responses for laboratory, engineering, and certification use. It is controlled via a PC using a graphical user interface (GUI) or application programming interface (API) over Ethernet, serving RFID developers, test laboratories, and manufacturers. The second item under consideration is described as the CISC RAIN Xplorer Inline 100, which is a high-speed UHF RFID testing device designed for automated production lines manufacturing RAIN RFID inlays and labels. It performs real-time testing of RAIN RFID tags, including reading, writing, encoding, and sensitivity measurements, at high throughput rates. Operating in the UHF band (approximately 800–1000 MHz), it supports adjustable transmit power, Electronic Product Code (EPC) and Tag Identifier (TID) reads, and frequency-dependent sensitivity testing. Designed for industrial integration, it communicates with machine controllers via Universal Serial Bus (USB) and General-Purpose Input/Output (GPIO) interfaces. This product does not perform network communication or modem functions; it generates controlled RFID test signals solely for quality inspection in production and quality assurance environments.

The third item under consideration is described as the CISC NFC Xplorer 110, which is a compact High Frequency (HF) RFID and Near Field Communication (NFC) test and measurement system for performance and conformance testing of NFC devices and tags. Functioning as both an active transmitter-receiver and a high-precision analyzer at 13.56 MHz, it provides measurements such as load modulation amplitude, minimum activation field strength, RF envelope characteristics, and protocol-level decoding for multiple NFC and HF RFID standards (e.g., ISO 14443 A/B, ISO 15693/180003, ISO 18092). A real-time sniffer mode allows detailed examination of reader–tag communication. This product is not a communication device; it generates controlled RF test signals and analyzes NFC/HF RFID responses for engineering, certification, and laboratory use. Controlled via Ethernet, it is utilized by NFC/RFID developers, test laboratories, and certification bodies. The fourth item under consideration is described as the CISC NFC Xplorer Inline, which is a high-speed HF/NFC test and measurement device for automated production lines and quality inspection of NFC labels and inlays. Operating at 13.56 MHz, it supports multiple NFC and HF RFID standards (e.g., ISO/IEC 14443A, ISO/IEC 14443B, ISO/IEC 15693). It performs fast read, write, encoding, and authentication operations, evaluating tags under variable conditions, and supports various NFC tag types and security features. Optimized for manufacturing environments requiring rapid, repeatable test cycles, it integrates directly into industrial production lines via USB and GPIO for automated pass/fail evaluation. This device does not function as a communication endpoint; it generates controlled RF test signals solely for measurement, inspection, and quality assurance processes, serving NFC tag manufacturers, integrators, and quality inspection facilities. In your letter, you suggest the applicable subheading for each of the four items to be within heading 8517, Harmonized Tariff Schedule of the United States (HTSUS). Heading 8517, HTSUS provides in relevant part for: “…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).” The items concerned are principally testing and measuring devices. They are RF test instruments used for performance, conformance, and communication analysis of RFID and NFC tags and readers. These devices generate controlled RF test signals and measure tag or reader responses for engineering, certification, and production line quality assurance. They incorporate a wireless transmission/reception function which is used to facilitate the measuring/testing function. The transmission/reception function would be considered a secondary or support function to that of the testing and measuring functions. Classification under heading 8517, HTSUS, is precluded because the devices concerned are composite goods (Section XVI Note 3 and Chapter 90 Note 3) which execute the principal function of testing and checking. The ability to transmit/receive would be considered the unit’s secondary or support function. Additionally, measurement apparatus of Chapter 90 are excluded from classification within Chapter 85 (Section Note XVI - 1. (m) excludes articles of Chapter 90). The applicable subheading for the CISC RFID Xplorer, the CISC RAIN Xplorer Inline 100, the CISC NFC Xplorer 110, and the CISC NFC Xplorer Inline will be 9031.80.8085, HTSUS, which provides for “Measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors; parts and accessories thereof: Other instruments, appliances and machines: Other: Other.” The general rate of duty will be free. The duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs.

For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Jason Christie at [email protected].
Sincerely,
(for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division