RE: The tariff classification and eligibility of the United States-Mexico-Canada Agreement (USMCA) of an Electronic Shelf Label from Mexico

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N363924 August 26, 2026 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification, Trade Programs TARIFF NO.: 8531.20.0040 Gena Haddock Expeditors Tradewin 795 Jubilee Drive Peabody, MA 01960 RE: The tariff classification and eligibility of the United States-Mexico-Canada Agreement (USMCA) of an Electronic Shelf Label from Mexico Dear Ms. Haddock: In your letter dated August 2, 2026, you requested a binding ruling on the tariff classification and eligibility of an Electronic Shelf Label (ESL) under the United States-Mexico-Canada Agreement (USMCA) on behalf of your client BOE Vision Electronic Technology Mexico SA de CV. The item concerned is identified as an ESL, part number EL01990101. This ESL is described as a wireless electronic display device designed for retail shelf-edge applications (i.e. an electronic pricing/shelf label). The device receives pricing and product data wirelessly, processes the data using embedded firmware, and displays limited product information on an electronic paper screen. The manufacturing process for the ESL begins by sourcing the completed Electronic Paper Display (EPD) module, as well as the front and rear plastic housings, a replaceable lithium manganese dioxide battery, adhesive tape, labels, and packaging materials from China. The completed EPD and other components are shipped to Mexico. In Mexico, the Main Printed Circuit Board Assembly (PCBA) is produced via a Surface Mount Technology (SMT) process. During this process, electronic components, such as multilayer ceramic capacitors (MLCCs), resistors, inductors, integrated circuits, diodes, connectors, oscillators, etc., sourced from various countries of origin, including China, Japan, the Philippines, United States, Taiwan, and Malaysia, are placed and soldered on a bare printed circuit board (PCB), sourced from China. Lastly, the final assembly of the ESL occurs in Mexico. The Mexican-produced PCBA is electrically connected to the Chinese-sourced EPD module. Firmware is then programmed into the device, the unit is assembled into its housing, labeled, subjected to testing, and packaged for export to the United States.
Classification: The applicable subheading for ESL, part number EL01990101 will be 8531.20.0040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric sound or visual signaling apparatus (for example, bells, sirens, indicator panels, burglar or fire alarms), other than those of heading 8512 or 8530; parts thereof: Indicator panels incorporating liquid crystal devices (LCD's) or light emitting diodes (LED): Other.” The 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. USMCA: The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note ("GN") 11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b) states: For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule as a "good originating in the territory of a USMCA country" only if- (i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries; (ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials; (iii) the good is a good produced entirely in the territory of one or more USMCA countries using non-originating materials, if the good satisfies all applicable requirements set forth in this note (including the provisions of subdivision (o)); Since the ESL contains non-originating ingredients, they are not considered a good wholly obtained or produced entirely in a USMCA country under GN 11(b)(i), nor are the products produced exclusively from originating materials per GN 11(b)(ii). Thus, we must determine whether the product qualifies under GN 11(b)(iii) and GN 11(o). The applicable tariff shift rule for goods classified under heading 8531, HTSUS, states, in relevant part:
A change to a good of subheading 8531.20 from any other good within that subheading or any other subheading. Based on the information provided, the EDP module, front and rear plastic housings, replaceable lithium manganese dioxide battery, adhesive tape, labels, and packaging materials of Chinese origin, and the materials sourced to create the PCBA in Mexico would be classified outside of heading 8531, HTSUS, as well as outside the noted subheading within the rule. As such, the non-originating items satisfy the tariff shift rule. The ESL, part number EL01990101 is eligible for preferential treatment under the USMCA upon importation to the United States. 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 Steven Pollichino at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division