The tariff classification of a wearable sensor device from China

N360915May 12, 2026CLA-2-90:OT:RR:NC:N1:105
CATEGORY: Classification
TARIFF NO.: 9031.80.8085
Pam BrownFuture Forwarding Company6180 Buffington RoadAtlanta, GA 30349RE: The tariff classification of a wearable sensor device from ChinaDear Ms. Brown:In your letter dated
April 22, 2026
, on behalf of your client, NaturalCycles USA Corporation, you requested atariff classification ruling. Descriptive literature was provided for our review.The item under consideration is described as the NC° Band, which is a wrist-worn wearable deviceengineered to promote a healthy lifestyle through the collection of various biomarkers. Constructed with aplastic housing and available with either silicone or nylon straps, it secures comfortably to the user’s wrist.The device is charged via a USB-C connector, with an LED indicator providing status updates. Keycomponents include a heart rate lens and a temperature measurement metal plate, and the device is supportedby a Bluetooth Low Energy 5.2 transceiver for efficient data transfer. Integrated sensors include anaccelerometer for motion and orientation data, a skin temperature sensor, an ambient temperature sensor, anda PPG (photoplethysmogram) sensor for heart rate monitoring. The NC° Band is designed with a service lifeof five years, during which it will receive periodic software updates to enhance functionality and ensuresystem stability.You have proposed classification within heading 8517, Harmonized Tariff Schedule of the United States(HTSUS), which 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 localor wide area network).” The item concerned is a fitness tracking wrist band that incorporates sensors used totrack various aspects of the user’s physical activity and bodily responses (i.e. pulse, temperature, bloodpressure, etc.). The fitness band utilizes a Bluetooth wireless transmission/reception function to transmit thedata collected to a tethered device. The transmission/reception function would be considered a secondary orsupport function to that of the fitness tracking function executed by the various sensors within the band. Thedevice concerned is a composite good (Section XVI Note 3 and Chapter 90 Note 3) which executes theprincipal function of tracking various health related metrics. The ability to transmit/receive would beconsidered the unit’s secondary or support function. Additionally, measurement apparatus of Chapter 90 are
excluded from classification within Chapter 85 per Section XVI Note 1(m) and telemeteringdevices/apparatus are excluded from heading 8517, HTSUS, based on the exclusions found in theExplanatory Notes. Therefore, classification within heading 8517, HTSUS, is not applicable. It is the opinion of this office that the tracking of the heart rate in heading 9029, HTSUS, and the temperaturereading of heading 9025, HTSUS, merits equal consideration to the accelerometer in heading 9031, HTSUS.Each of the functions may be utilized at any moment to assist the wearer with their activity tracking.Therefore, classification will be determined based on the competing heading that occurs last in numericalorder. General Rules of Interpretation (GRI) 3(c) noted.The applicable subheading for the NC° Band will be 9031.80.8085, HTSUS, which provides for “Measuringor checking instruments, appliances and machines, not specified or included elsewhere in this chapter; profileprojectors; parts and accessories thereof: Other instruments, appliances and machines: Other: Other.” Thegeneral rate of duty will be free.The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenienceand are subject to change. The text of the most recent HTSUS and the accompanying duty rates are providedat https://hts.usitc.gov/.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to theclassification stated above, the merchandise covered by this ruling may also need to be reported with eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems 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 asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Jason Christie at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division