Protestant filed three protests. The merchandise primarily at issue in the subject entry and protest, is stated to be toner cartridges dedicated for use in photocopy machines. The invoice sets forth the following merchandise: Product No. Quantity Description XEX6R244 290 Toner XEX6R752 42 Toner 5614 XEX6R364 34 Toner 5318 XEX6R379 100 Toner 5312 Copies of product catalogs indicate that the above referenced product numbers are cartridges of Xerox brand toner for certain copier models. In addition, some entries contained products designated as “6R229, 6R301, and 6R206” which are stated to be toner and not parts dedicated for use in photocopy machines. Protestant also states that a number of entries contain products identified as Hewlett Packard printer cartridges, and Panasonic drum toners (listed as UNLUG 3313 and UNLUG 3309). Some of the entries also included lubricating oil. Since these items do not appear to be covered in entries subject to the protest forwarded for further review, these particular goods will not be discussed. The merchandise was entered under subheading 9801.00.10, HTSUS, from Canada, on May 22; June 3, 12, and 18; and September 11, 1998. Customs issued a Notice of Action on February 24, 1999, indicating a rate advance for the merchandise because no American manufacturer's affidavit was provided, and no response was provided concerning drawback. The Notice of Action listed certain entries and that the entries would be classified under subheading 9801.00.80, HTSUS, with assessment for the drawback amounts per memorandum 225796 dated October 30, 1995. The entries were liquidated on April 16, 1999, and the protest was timely filed on July 14, 1999.

Application for Further Review of Protest No. 0712-99-100157

Subheading 9801.00.80 Subheading 9801.00.80, HTSUS, provides as follows: Articles previously exported from the United States which--except for U.S. note 1 of this subchapter--would qualify for free entry under one of the foregoing items and are not otherwise free of duty . . . U.S. note 1(a) of Subchapter I, Chapter 98, HTSUS, states that the provisions in the subchapter (except subheadings 9801.00.70 and 9801.00.80) shall not apply to any article that is exported with the benefit of drawback. The rate of duty is as follows: …the sum of any duty and internal revenue tax imposed upon the importation of like articles not previously exported, but in no case in excess of the sum of (a) any customs drawback proved to have been allowed upon such exportation of the article, and (b) any internal-revenue tax imposed, at the time such article is entered, upon the importation of like articles not previously exported. In determining the duty under this provision, it is noted that the term “like articles” refers to foreign articles not previously exported. U.S. Note 2(a), Subchapter I, Chapter 98, HTSUS, provides, in part, that for purposes of subheading 9801.00.80, the rate of duty in no case shall be more than the duty and tax that would apply if the article were wholly of foreign origin. Pursuant to the Notice of Action, the merchandise was classified under subheading 9801.00.80, HTSUS, with amounts indicated for drawback. Protestant claims that if the merchandise as a foreign article is free of duty, no duty may be assessed under the Chapter 98 tariff provision. In HRL 559161 dated September 19, 1995, Customs found that cigarettes, neither advanced in value nor improved in condition while abroad, and the type of merchandise normally subject to a drawback allowance in connection with its exportation from the U.S., were classifiable in subheading 9801.00.80, HTSUS. In determining the duty to be paid upon importation, it was incumbent upon Customs to determine the drawback allowed upon exportation of the cigarettes, either from actual records, or in accordance with the methodology provided in 19 CFR 10.3(a)(1). However, in Headquarters Ruling Letter (HRL) 224025 dated October 22, 1992, Customs considered tractors assumed to be free of duty under heading 8701.30.50, HTSUS, under the Canadian Free Trade Agreement. Customs stated that if the tractors were free of duty under heading 8701.30.50, HTSUS, they would not meet the qualifications of subheading 9801.00.80, HTSUS, and would be classifiable under the appropriate subheading under heading 8701, HTSUS. In this case, protestant claims that the toner cartridges are duty-free under subheadings 9009.90.50 and 9009.90.70, HTSUS. The toner, listed as 6R206, 6R229, and 6R301, is alleged to be classified under subheading 3707.90.32, HTSUS. In accordance with U.S. Note 2(a), Subchapter 1, Chapter 98, HTSUS, and HRL 224025, we find that to the extent the toner cartridges are duty free or the duty on the toner is less than the amount assessed under subheading 9801.00.80, HTSUS, the goods may be classified in their appropriate tariff provisions within Chapters 1 -97, HTSUS. Classification Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation (GRIs), taken in order. GRI 1 states in part that, for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes, and provided the headings or notes do not require otherwise, according to GRIs 2 through 6. Mita Copystar, Inc. v. United States, 966 F. Supp. 1245 (CIT 1997), rehearing denied 994 F. Supp. 393 (CIT 1998), reversed 160 F.3d 710 (Fed. Cir. 1998), and CIT decisions vacated CIT Slip Opinion 99-4 (1999), involved the classification of toner cartridges which are shaped to fit into specific electrostatic photocopiers. Customs classification of the articles was as chemical preparations for photographic uses in subheading 3707.90.30, HTSUS (currently broken out in subheadings 3707.90.31 and 3707.90.32, HTSUS). The final court decision held the proper classification to be as parts and accessories of electrostatic photocopying apparatus in subheading 9009.90.00, HTSUS (currently broken out into four subheadings within subheading 9009.90, HTSUS). The Court of Appeals for the Federal Circuit based its decision on Note 2(b), Chapter 90, HTSUS (this Note provides for the classification of parts and accessories of articles of Chapter 90). (Before so deciding, the Court held that a Note for Section VI (including heading 3707, HTSUS) did not require classification in that heading, reversing the CIT which had held that the Note did require classification in heading 3707; there is no such note for heading 3215, HTSUS.) The Court set forth the following factors resulting in the determination that the cartridges were parts of photocopying apparatus (160 F.3d at 712-713): The cartridges are sold with toner inside; they remain with the toner throughout its use by the photocopier; they are the standard device for providing toner to the photocopier and thus play an essential role in the functioning of the machine; and they are not designed for reuse. Accordingly, protestant claims that based upon Mita Copystar, the toner cartridges dedicated for use in photocopy machines are properly classfied under subheading 9009.90.50 or 9009.90.70. Protestant states that while the invoices indicate that the product in question is toner, the invoices are incomplete in their description and the goods (with the exception of products 6R229, 6R301 and 6R206 which are toner), in fact, are toner cartridges. We agree with protestant. Based on the product catalogs submitted, some of the item numbers are described as cartridges of specified sizes. Accordingly, to the extent you may wish to verify that the "[t]he cartridges [in this case] are sold with toner inside; they remain with the toner throughout its use by the photocopier; they are the standard device for providing toner to the photocopier; and they are not designed for reuse", the goods are classified in subheading 9009.00.50 or subheading 9009.00.70, HTSUS. Mita Copystar, 160 F.3d at 712,713. The toner would be classified under subheading 3707.90.32, HTSUS, to the extent the duty assessed is less than that determined under subheading 9801.00.80, HTSUS.


Internal Advice Request No. 06/023; Classification of positive and negative photoresists

photographic plate for semiconductor
photomask blank
photomask for semiconductor
photoresist developer


The tariff classification of an OPC Drum for a laser printer from Japan. The merchandise under consideration involves a model ND-822 DX-102 organic photoconductor (OPC) drum that is designed and used with laser printers. The OPC drum is an essential part of a laser printer and is used to convert light signals to an electrostatic latent image. The light source of a laser printer is a semiconductor laser diode which scans (exposes) the surface of the photoconductor directly and is controlled by an output signal from the computer. Model ND-822 consists of an aluminum cylinder that is approximately 10.25 inches in length, and 1.2 inches in diameter, with a uniform coat of OPC which has a high sensitivity to the light emitted by a laser diode. The OPC coat has extended durability in the course of normal EP functions which are; being charged by the DC corona, imaged by a laser beam, image developing by toner and image transference to paper. The drum is then cleaned by a urethane blade and the residual charge is erased by a flash of light. As a laser diode emits near-infrared radiation (practically 780-830 nm), the OPC for the laser printer should have a higher sensitivity at the wavelength area. This means that the OPC for a laser printer has a lower sensitivity at the visible light area. OPC drums that are designed for copiers are therefore different from the model before us since copier drums are designed to have a panchromatic sensitivity of 450- 600nm.

The applicable subheading for the model ND-822 DX-102 OPC drum will be 8473.30.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts and accessories of the machines of heading 8471 not incorporating a cathode ray tube. The rate of duty will be free.


NY F89232 July 20, 2000 CLA-2-84:RR:NC:MM:110 F89232 CATEGORY: Classification TARIFF NO.: 8473.30.5000 Mr. Mitchell Neriah 415 So. Prospect Ave. Ste. 110 Redondo Beach, CA 90277 RE: The tariff classification of the "Volume Board", a printed circuit board from Japan. Dear Mr. Neriah: In your letter dated June 26, 2000, on behalf of your client Toshiba America Information Systems, Inc. (TAIS), you requested a tariff classification ruling. The merchandise under consideration is TAIS part number B36084712A, "Volume Board"; a sample was submitted with your ruling request. The "Volume Board" is composed of a rigid plastic impregnated printed circuit board with a number of passive components. There are two non-printed fixed resistors, a non-printed chip capacitor, a non-printed connector and one variable resistor with a plastic wheel for adjustment. When installed in the computer, the plastic wheel of the variable resistor is exposed along the top lid side panel. The function of this unit is to provide a means of adjusting the brightness level of the LCD display by turning the wheel. Although the part is named "Volume Board", it does not control any volume features on the notebook PC. This item is specifically and exclusively designed for use with Toshiba notebook computers. Section XVI, Additional U.S. Note 1 of the Harmonized Tariff Schedule of the United States (HTS) states "For the purposes of this section, the term "printed circuit assembly" means goods consisting of one or more printed circuits of heading 8534 with one or more active elements assembled thereon…." The "Volume Board" does not have any active elements; therefor it does not meet the requirement of a printed circuit assembly under Additional U.S. Note 1, Section XVI. The applicable subheading for the "Volume Board", TAIS part number B36084712A, will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for "Parts and accessories (other than covers, carrying cases and the like) suitable for use solely or principally with machines of headings 8469 to 8472: Parts and accessories of the machines of heading 8471: Not incorporating a cathode ray tube: Other." The rate of duty will be free. 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 Eileen S. Kaplan at 212-637-7019. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division


The tariff classification of digital input/output mounting boards assembled in Mexico. The merchandise under consideration involves digital input/output mounting boards (I/O boards) which provide logic- level control signals to a computer. Two sample I/O boards, a model PB-4 and a model PB-32Q have been submitted for review. The logic-level control signals enter the board through single screw terminal blocks in the two submitted samples. In other models the logic-level control signals enter the board through a 50-circuit card-edge connector. All digital input/output boards require DC power for proper operation. There are four basic models; 8, 16, 24, and 32 position boards. These input/output boards are integral parts used in an input/output unit for automatic data processing machines, or units thereof.

The applicable subheading for the digital input/output mounting boards (I/O boards) will be 8473.30.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts and accessories of the machines of heading 8471 not incorporating a cathode ray tube. The rate of duty will be free.


The tariff classification of a Chips "PCTV Board" from Japan The merchandise under consideration involves a board that makes possible the simultaneous viewing of one live television source in a window and running application programs such as spreadsheets, word processors, or desktop publishing in other windows. The PCTV board is a single card full motion video display card with a television tuner and audio processing circuitry. It is designed to be incorporated into the personal computer, and normally is connected next to the VGA card in an empty 16-bit board slot. It allows display of a live video window from cable or broadcast television to be merged with VGA graphics on one display monitor. This enhancement or accessory board requires the Microsoft Windows 3.0 or greater operating system software to run Chips TV software.

The applicable subheading for the Chips "PCTV Board" will be 8473.30.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts and accessories of the machines of heading 8471, not incorporating a cathode ray tube. The rate of duty will be free.


The tariff classification of printed circuit board assemblies for tape drives from Thailand. The merchandise under consideration involves various models of printed circuit board assemblies that are designed for use with peripheral tape drives. The tape drives are secondary data storage devices that work in conjunction with a primary storage device, such as the hard drive of a host computer. The printed circuit boards all contain such components as various integrated cicuits, transistors, diodes, resistors, capacitors, switches, LED's, and other electronic components and materials. Model #2002500-001 microprocessor board for the 1300XL tape drive is the primary controller and SCSI interface board that performs all of the electronic and data handling functions. Model #2002600-003 Epsilon Servo board that is used with the model 1300XL and 2000 tape drives is designed to control the four motors of the tape drive mechanism. Model #2002400-015 Epsilon Format board for the 1300XL and 2000 tape drive performs all of the data formatting functions such as read/write electronics, data separation and audio format electronics. Model #2002800-002 Data Compression board for the model 2000 tape drive performs the data compression and encoding functions. The Model 3100 and 3200 boards use a higher level of integration to put the functions of the microprocessor, servo, and format boards all onto a single board designed to fit into a smaller product outline.

The applicable subheading for the model 2002600-003 servo boards will be 8537.10.0050, Harmonized Tariff Schedule of the United States (HTS), which provides for boards and panels, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity: For a voltage not exceeding 1,000 V..other: panel boards and distribution boards. The duty rate will be 5.3 percent ad valorem. The applicable subheading for all of the other models of boards will be 8473.30.4000, HTS, which provides for parts and accessories of the machines of heading 8471 not incorporating a cathode ray tube. The duty rate will be free. Articles classifiable under subheading 8537.10.0050, HTS, which are products of Thailand, are entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations.


The tariff classification of components for an "InfoPak Information System" from Mexico. The merchandise under consideration involves components of a computer based data system, called the "InfoPak Information System", whose purpose is to give users in remote locations the ability to access information by means of a portable display device. The specific items in the system include an assembled printed circuit board, called an "Internal Card", an external drive, called an "Infoloader", and a portable LCD/keyboard unit called an "InfoReader". Some of these components will also be shipped in a "kit" format and sold and marketed as a retail set. Some of the most common end uses for this system will be real estate offices for displaying real estate listings, or for showing such data as telephone directories, flight schedules or similar data. The Internal Card is a printed circuit board which will be placed inside of an IBM compatible PC and provides the PC with the hardware capability to address data onto the memory card via the external drive. The InfoLoader contains a 68 pin memory card connector housed in a stand alone 6.5" x 4.25" x 1.75" metal case. The purpose of this unit is to update the InfoCards via a 50 pin ribbon that connects the InfoLoader to the printed circuit board installed in the PC. This unit is not a storage device since it is designed to transcribe data from the PC onto the InfoCard. The InfoReader is a hand-held, fold open display device measuring 7.75" x 3.25" x 1.25". On one side of the unit is an LCD display and on the other side is a keyboard with a ten key pad plus directional keys and an enter key. It is battery powered in normal use but does include an AC adapter for outside power. The InfoReader accepts programmed InfoCards and allows the user to bring up on the LCD certain pieces of information contained in the card memory. This unit is therefore a combination display and input device. The InfoLoader Kit will be imported packaged for retail sale and will contain one Internal Card, one InfoLoader, one ribbon cable, and one diskette of U.S. origin that contains the software driver program that controls the interface between the PC and InfoLoader. Noting GRI-3 (b), the essential character of this set appears to be exemplified by the Internal Card, due in part to its cost and proprietary technical nature. The InfoReader Kit is made up of one InfoReader and InfoCard, packaged together for retail sale when imported. The InfoCard consists of a flash EPROM memory card of credit card size which in use is inserted into the InfoReader and contains an operating program and the data to be displayed by the InfoReader. Noting GRI-3 (c), this set does not appear to include a component that gives the set its essential character.

The applicable subheading for the Internal Card will be 8473.30.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts and accessories of the machines of heading 8471 not incorporating a cathode ray tube. The rate of duty will be free. The applicable subheading for the InfoLoader will be 8471.99.9000, HTS, which provides for machines for transcribing data onto data media in coded form and machines for processing such data, not elsewhere specified or included. The rate of duty will be 3.7 percent ad valorem. The applicable subheading for the InfoReader will be 8471.92.1090, HTS, which provides for combined input/output units. The rate of duty will be 3.7 percent ad valorem. The applicable subheading for the InfoLoader Kit will be 8473.30.4000, HTS, which provides for parts and accessories of the machines of heading 8471 not incorporating a cathode ray tube. The rate of duty will be free. The software diskette, noting Legal Note 6 to Chapter 85, will be separately classified under HTS number 8524.90.4080. The rate of duty will be 9.7 cents per square meter of recording surface. The applicable subheading for the InfoReader Kit will be 8473.30.4000, HTS, which provides for parts and accessories of the machines of heading 8471 not incorporating a cathode ray tube. The rate of duty will be free. Articles classifiable under subheading 8471.99.9000, 8471.92.1090, and 8524.90.4080, HTS, which are the products of Mexico, are entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations.


The tariff classification of a printed circuit board assembly from a Foreign Trade Subzone. The merchandise under consideration involves a printed circuit board assembly that is a subassembly of a card cage used in the controller of a tape or disk peripheral device. The PCB assembly consists essentially of a board that has attached to it, two connectors, 48 capacitors, 4 screws, one housing shroud, and a label. The assembly is approximately four inches in length, and one inch in width. It appears to be designed and principally used with automatic data processing machines and units thereof.

The applicable subheading for the printed circuit board assembly will be 8473.30.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts and accessories of the machines of heading 8471 not incorporating a cathode ray tube. The rate of duty will be free.


In HQ 957189, the anti-reflection silicon wafers were described as follows: “… Kyocera will import Japanese manufactured multi-crystalline silicon wafers [into the United States]. The manufacturing operation in Japan consists of: 1. silicon wafer fabrication; 2. surface treatment; 3. P/N junction formation; 4. back N type layer etching; 5. back surface field formation; and 6. anti-reflection coating. After importation into the U.S., the anti-reflection coated silicon wafers will be further manufactured into a complete solar panel. The manufacturing operations to be performed in the U.S. entail: 1. patterning; 2. metalization; 3. solder coating; 4. cell inspection; 5. lead wiring; 6. string formation; 7. lamination; 8. curing; 9. framing; 10. joint box fixing; and 11. inspection. The complete solar panels will then be exported to Mexico and/or Canada.”


The tariff classification of a video enhancement board from Germany. The merchandise under consideration involves a model "Video Machine" enhancement board which when added to a computer, is used to mix and edit video material. Specifically, the Video Machine is a single printed circuit board which is plugged into any open expansion slot in a desk-top computer. It is a 16-bit AT bus board for PC compatible computers or a Nubus board for Apple Macintosh computers. The function of the enhancement board is to enable a computer to mix and edit real-time video signals. The "Video Machine" is imported in a set packaged for retail sale and includes the following: the video enhancement board; cable splitter; five software floppy disks; and an operation manual. The essential character of this retail set is exemplified by the video enhancement board, noting GRI-3 (b) of HTS. Noting Legal Note 6 to Chapter 85 of HTS, the software disks are separately classified.

The applicable subheading for the "Video Machine" retail set will be 8473.30.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts and accessories of the machines of heading 8471. The rate of duty will be free. The applicable subheading for the recorded floppy disks will be 8524.90.4080, HTS, which provides for other recorded media. The rate of duty will be 9.7 cents per square meter of recording surface.


The tariff classification of foldable solar chargers from China, duty allowance under HTSUS 9802.00.8068, and country of origin marking. In addition, you raised questions regarding the eligibility of a duty allowance under HTSUS 9802.00.8068 and country of origin marking on behalf of your client OPS America, Inc. Your letter states that OPS America, Inc. will contract with a factory in China to assemble foldable solar chargers using American manufactured solar modules and other foreign manufactured components. The solar modules, which will be manufactured in the United States by a company known as PowerFilm, will be provided to the factory in China, free of charge, to be used in the assembly of foldable solar chargers. After assembly in China, the foldable solar chargers will be imported into the United States and sold to PowerFilm Inc. When the solar modules are exported to China, they will be in a condition ready for assembly without further fabrication. After assembly into the foldable solar chargers, the solar modules fully retain their physical identity and will not be advanced or improved in condition except by being assembled into the foldable solar chargers. The foreign components that are used in the assembly process are cut-to-size fabric, printed circuit boards, diodes, polyswitches, wires with overmolds, connectors, terminals, junction boxes, Velcro, grommets, labels, and cable seals. The function of the foldable solar chargers is to provide lightweight, portable, and remote power for laptops, cell and satellite phones, GPS units, etc., in difficult and diverse environments. The foldable solar chargers will be purchased at retail directly from PowerFilm Inc., or from one of their authorized re-sellers. You suggested that the proper classification of the foldable solar chargers is within subheading 8541.40.6020, which provides for “Other diodes: Other: Solar cells: Assembled into modules or made up into panels.” However, while the solar modules that are being exported to China to be utilized in the assembly process would qualify for classification under that subheading, the foldable solar charger being imported into the United States is not a solar module, but rather a static converter, to be specific it is a charger, which is provided for in heading 8504. As such, 8541.40.6020 is inapplicable.

The applicable subheading for the foldable solar chargers will be 8504.40.9550, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Static converters: Other: Rectifiers and rectifying apparatus: Other. The rate of duty will be 1.5 percent ad valorem. You also inquire as to applicability of subheading 9802.00.8068, HTSUS, to the imported foldable solar chargers.  Subheading 9802.00.80, HTSUS, provides a partial duty exemption for articles assembled abroad in whole or in part of fabricated components, the product of the United States, which were exported in condition ready for assembly without further fabrication, have not lost their physical identity in such articles by change in form, shape or otherwise, and have not been advanced in value or improved in condition abroad, except by being assembled and except by operations incidental to the assembly process, such as cleaning, lubrication, and painting. All three requirements of subheading 9802.00.80, HTSUS, must be satisfied before an article may receive a duty allowance. An article entered under this tariff provision is subject to duty upon the full value of the imported assembled article, less the cost or value of such U.S. components, upon compliance with the documentary requirements of Section 10.24, Customs Regulations (19 C.F.R. 10.24). Section 10.14(a), Customs Regulations (19 C.F.R. 10.14(a)), states that the U.S. components must be in a condition ready for assembly without further fabrication at the time of their exportation from the United States to qualify for the exemption. Components will not lose their entitlement to the exemption by being subjected to operations incidental to the assembly, either before, during, or after their assembly with other components. Section 10.16(a) Customs Regulations (19 C.F.R. 10.16(a)) provides that the assembly operation performed abroad may consist of any method used to join or fit together solid components, such as welding, soldering, riveting, force fitting, gluing, laminating, sewing, or the use of fastener. Based on the information you have provided, the assembly process meets the standard for reduced duty treatment in HTSUS heading 9802. Therefore, the foldable solar chargers may enter under subheading 9802.00.8068, HTSUS, with allowances in duty for the cost or value of the U.S. components, upon compliance with the documentary requirements of 19 C.F.R. 10.24. Lastly, your request addresses the country of origin marking of the foldable solar chargers. You indicate that the importer intends to mark the goods using a label affixed to the outside of the charger. The label will include PowerFilm’s name/logo and website URL, the part number, and the words “Assembled in China. Solar Modules Made in the U.S.A.” A marked sample container was not submitted with your letter for review. The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article. Part 134, Customs Regulations (19 CFR Part 134), implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.41(b), Customs Regulations (19 CFR 134.41(b)), mandates that the ultimate purchaser in the U.S. must be able to find the marking easily and read it without strain. Section 134.1(d), defines the ultimate purchaser as generally the last person in the U.S. who will receive the article in the form in which it was imported. If an imported article is to be sold at retail in its imported form, the purchaser at retail is the ultimate purchaser. In this case, it appears that the ultimate purchaser of the foldable solar chargers is your customer, PowerFilm, Inc. While it is true that the foldable solar chargers are assembled in China and utilizes solar modules of U.S. origin, a more suitable country of origin marking would be “Assembled in China with U.S.A. solar modules and other foreign components”, or “Assembled in China with solar modules manufactured in the U.S.A. and other foreign components” for the imported foldable solar chargers.


The tariff classification of a RK Series Driver, an Alpha Step Plus Integrated Driver and Controller, an EMP Series controller, a SG Stepping Motor Controller, and a BLF Series Driver from Japan and Singapore On January 29, 2009, National Import Specialists Linda M. Hackett and Thomas Campanelli of this office participated in a conference call with you and representatives of Oriental motors, USA, Corporation, Angelo Cabanban and John Wong, to obtain additional information which was originally submitted. The merchandise subject to this ruling is a RK Series Driver, an Alpha Step Plus Integrated Driver and Controller, an EMP electric motor controller, a SG Stepping motor controller, and a BLF Series Driver. Samples of each of these items were furnished for classification purposes and are being returned as per your request. The RK Series Driver is identified in your letter as Model RKD514L-A. From the sample and information you provided, the RK Series Driver is a solid state, 5-phase stepping motor and driver package, rated for up to 230 volts (V). This device consists of two printed circuit boards (PCBs) populated with active and passive components within a metal housing measuring approximately 5¼ inches high by 2¼ inches wide by 4¾ inches deep. The front panel features a terminal strip, one “D” type data connector, one three-lever DIP (Dual In-Line) switch and four rotary switches used to control the motor. The RK Series Driver receives AC power input and delivers DC power to an electric motor. This driver does not feature a programmable memory; adjustments controlling the motor are performed by the individual switches on the front panel. The Alpha Step Plus Integrated Driver and Controller is identified in your letter as Model ASD24A-AP. From the sample and information you provided, this device is a solid state motor driver with integrated controller, and is rated for up to 230 V. This device consists of two PCBs populated with active and passive components within a metal housing measuring approximately 6 inches high by 1¾ inches wide by 4¾ inches deep. The front panel features a terminal strip, one RJ type socket connector, two multi-pin socket connectors and two “D” type data connectors. The Alpha Step Plus Integrated Driver and Controller receives AC power input and delivers DC power to an electric motor. This driver does not feature a programmable memory; all adjustments to control a motor must come from a separate device via the data connectors. The EMP Series controller is identified in your letter as Model EMP401-2. The sample, which measures approximately 1½ inches high by 5½ inches wide by 3¾ inches deep, contains a printed circuit assembly within a plastic housing. Located on the back of the device is an LED monitor display to indicate power or alarm, a jack connection port, an input/output (I/O) signal connector, and an Axis-1 and an Axis-2 driver connector. Based on the information you provided, this device is called a programmable motion controller; however, it is a solid state device that simply transmits data. It does not open or close a circuit nor provide power to a motor. The EMP Series controller is an interface device that receives data from an I/O control and transmits that data to a motor driver. An example of the environment in which it communicates data was provided in your submission, i.e., when used with a golf club shaft deflection measuring machine. In that instance, the EMP electric motor controller sends (transmits) commands to the motors that move the measuring apparatus along the golf club length. The SG Stepping Motor Controller is identified in your letter as Model SG8030J-D. From the sample and information you provided, it is a solid state device that switches between two control methods according to the application; sequential positioning and data selection positioning. It measures approximately 4½ inches high by 1¾ inches wide by 2¾ inches at the bottom of the device and 1¾ deep at the top of the device. Located on the top of the device is a data display, three LEDs that indicate an external input mode, program mode, or a test mode, and user interface buttons/switches to enable the user to accomplish some of the device’s programming functions. This SG Stepping Motor Controller does not provide power to operate a motor. However, the buttons/switches enable the user to regulate the speed of pulses, thus regulating the speed of a motor. The BLF Series Driver is identified in your letter as Model BLFD60A2. From the sample and information you provided, the BLF Series Driver is a brushless DC 3-phase motor driver with a digital operator programmable controller, rated for up to 240 V. This device consists of a metal base with a plastic enclosure measuring approximately 5¼ inches high by 3¾ inches wide by 3½ inches deep. On the front of the enclosure are four terminal strips, one rotary switch, and a detachable digital operator with six momentary contact switches and digital display. Beneath a removable cover are two plug-in PCB connectors and two slide switches. Internally there are four PCBs, three of which are populated with active and passive components. The BLF Series motor driver receives AC power input and delivers DC power to an electric motor. The controls on the front panel provide the operator with full motor driver functions and can be programmed with its internal memory for multi-speed operations with four speed setting methods. In your ruling request you suggest the RK Series Driver (Model RKD514L-A) and Alpha Step Plus Integrated Driver and Controller (Model ASD24A-AP) is correctly classified under subheading 8504.40.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Motor drive controllers for electric motors.” However, the RKD514L-A and ASD24A-AP not only control electric motors, they are the sole provider of power to the motor. Therefore, the RK Series Driver and Alpha Step Plus Integrated Driver and Controller are provided for under heading 8537, HTSUS, as apparatus for electric control and the distribution of electricity. As such, subheading 8504.40.4000, HTSUS is inapplicable. You suggested that the EMP Series controller (Model EMP401-2) is correctly classified under subheading 8504.40.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Motor drive controllers for electric motors.” However, the EMP Series controller does not control the speed or the torque of an electric motor. It is a device that transmits data. Apparatus for the transmission of data is provided for in heading 8517, HTSUS. As such, subheading 8504.40.4000, HTSUS is inapplicable. You suggested that the SG Stepping Motor Controller (Model SG8030J-D) is correctly classified under subheading 8537.10.9060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Programmable controllers.” However, the SG Stepping Motor Controller does not feature a programmable memory for the storage of instruction to control or for the distribution of power to a motor; rather it is a device that carries out the function of a speed drive controller for an electric motor by regulating the speed of a motor. Speed drive controllers for electric motors are provided for in heading 8504. As such, subheading 8537.10.9060, HTSUS is inapplicable.

The applicable subheading for the RK Series Driver (Model RKD514L-A) and the Alpha Step Plus Integrated Driver and Controller (Model ASD24A-AP) will be 8537.10.9070, HTSUS, which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 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% ad valorem. The applicable subheading for the EMP Series (Model EMP401-2) will be 8517.69.0000, HTSUS, which provides 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): Other.” The rate of duty will be free. The applicable subheading for the SG Stepping Motor Controller (Model SG8030J-D) will be 8504.40.4000, HTSUS, which provides for “Speed drive controllers for electric motors.” The rate of duty will be 1.5 percent ad valorem. The applicable subheading for the BLF Series Driver (Model BLFD60A2) will be 8537.10.9060, HTSUS, which provides for “Boards, panels, consoles…and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Programmable controllers.” The general rate of duty will be 2.7 percent ad valorem.


The tariff classification of miniature voltage controlled oscillator (ID # G01525) from Japan The merchandise subject to this ruling is a self contained miniature voltage controlled oscillator (ID # G01525). It produces clean 1.485 GHz reference clock signals for deserializers and serializers. The control voltage range is from 1.0 volts to 1.5 volts. The G01525 frequency can be pulled approximately 32 MHz for every one volt of control. The voltage controlled oscillator is an electronic oscillator designed to be controlled in oscillation frequency by a voltage input. The frequency of oscillation is varied by the applied direct current (DC) voltage. While modulating, signals may also be fed into the voltage controlled oscillator to cause frequency modulation (FM) or phase modulation (PM). It generates a signal, but is not a signal generator. This device is used on a printed circuit board in conjunction with devices that convert parallel data to serial data. It consists of a piezo-electric crystal, which is machined to result in a specific frequency range and then mounted on a printed circuit board along with capacitors and resistors and reflowed through a soldering process. A metal can (lid) is attached and electrical testing occurs. The voltage controlled oscillator outputs a square wave voltage output with a frequency proportional to the input voltage applied; the higher the applied direct current (DC) input voltage, the higher will be the frequency of the resulting square wave.

The applicable subheading for the miniature voltage controlled oscillator (ID # G01525) will be 8504.40.9580, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical transformers , static converters (for example rectifiers) and inductors; parts thereof: Static converters: Other: Other.” The rate of duty will be 1.5 percent ad valorem.”


The tariff classification of uninterruptible power supplies (UPS), from Japan and China (“HICAM”). The merchandise subject to this ruling is two uninterruptible power supplies (UPS). They are identified as Item Number 5533457-100 and Item Number DKC-F460I-42. HIMAC is a manufacturer and importer of disk array systems and equipment. Disk arrays are data storage systems containing multiple physical hard drives. These arrays are redundant arrays of independent disk, or RAID devices. HICAM’s disk arrays have previously been ruled upon as "Automatic data processing machines and units thereof…Storage units” of heading 8471. The two UPS devices ruled upon in this letter are for assembly into HICAM’s disk arrays. Within HICAM’s disk array, the UPS devices provide power to the system in the event of interruptions in, or failures of, the external power supply, i.e., black outs, sags, brown outs. When an external power failure or disruption is detected, the UPS is automatically activated. For short interruptions in power (approximately 200 milliseconds or less), the power supplies maintain full system functionality. For longer power interruptions, the devices initiate a controlled shut down of the disk array subsystem, while providing power to the disk array control systems, i.e., cache memory, and shared memory. This controlled shutdown prevents potential loss or damage of data files. The UPS Item Number 5533457-100 is an uninterruptible battery backup device manufactured in a specific size and shape to permit assembly into HICAM’s R600 disk array frame through a backplane connection, where a series of these UPS devices will be mounted. This device is comprised of circuit boards containing various resistors and capacitors, a device to control and check the charge and discharge of battery and input/output power, a step down DC-DC converter, user interface with a switch and LED lights, and nickel-hydride batteries. The power supply receives 12 volts of DC input power and converts that power to 8-12 volts DC for supplying power from the batteries to the cache memory and logic devices in the R600 controller frame (also knows as “DKC”). The power supply also provides 12 volts DC power to the batteries for recharging. The maximum input power is 15 watts, and the maximum output power is 700 watts. This UPS monitors the input power and, if a fluctuation is detected, it provides the precise power specifications needed by the system to maintain the DKC cache memory and logic device for one minute after the detected power failure. This provides the system enough time to perform a controlled shut down. The UPS Item DKC-F460I-42 is for the RAID450 disk array, an earlier version of the R600 disk array described above. Functionally, it is the same UPS device as Item Number 5533457-100 described above, but is not contained in a single unit. The printed circuit board for this UPS is inserted into a backplane and communicates with and controls the batteries through the backplane. Due to space limitations, the battery is located in another part of the RAID450 frame from the circuit board. This kit contains two printed circuit boards and two batteries. One printed circuit board and one battery make up a complete UPS. However, the kit includes two of each because the RAID450 device requires multiple UPS devices. The circuit board contains various resistors and capacitors, a device to control and check the charge and discharge of battery and input/output power, a step down and a step up DC-DC converter, user interface with a switch and LED lights, and nickel-hydride batteries. The power being supplied to the device is 5 volts DC and 13 volts DC from the batteries. The device converts that power to 3.3 volts DC at 8.4 watts for the cache memory and 13 volts DC at 47 watts for charging the batteries, with a maximum output of 55.4 watts. As with Item No. 5533457-100, the DKC-F460I-42 monitors the input power and, if a fluctuation is detected, provides the precise power specifications needed by the system to maintain the cache memory and logic device for one minute after the detected power failure. This provides the system enough time to perform a controlled shut down. The printed circuit board and battery work together through the backplane to act as a functional unit within the disk array frame.

The applicable subheading for the uninterruptible power supply (UPS), Item Number DKC-F460I-42 will be 8504.40.6007, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Electrical transformers, static converters (for example, rectifiers) and inductors… Static converters: Power Supplies for automatic data processing machines or units thereof of heading 8471: Suitable for physical incorporation into automatic data processing machines or units thereof of heading 8471: With a power output exceeding 50 W but not exceeding 150 W." The rate of duty will be free. The applicable subheading for the uninterruptible power supply (UPS), Item Number 5533457-100 will be 8504.40.6018, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Electrical transformers, static converters (for example, rectifiers) and inductors… Static converters: Power Supplies for automatic data processing machines or units thereof of heading 8471: Suitable for physical incorporation into automatic data processing machines or units thereof of heading 8471: Other." The rate of duty will be free.


The tariff classification of a PowerCap and a PowerCap with Crystal from the Philippines The merchandise under consideration is a PowerCap and a PowerCap with Crystal. The product literature also refers to the PowerCap as DS9034PC/PCI and the PowerCap with Crystal as DS9034PCX. Samples of each of these devices were submitted for classification purposes. The DS9034PC/PCI PowerCap is a lithium power source designed to provide 10 years of battery backup power for NV (non-volatile) SRAMS in Dallas Semiconductor’s PowerCap Module (PCM) package. It snaps directly onto a surface-mounted PowerCap Module base to form a complete NV SRAM Module. The DS9034PCX PowerCap with Crystal a lithium power source designed to provide 10 years of battery backup power for NV (non-volatile) timekeeping RAMs in Dallas Semiconductor’s surface-mountable PowerCap Module (PCM) package. After the PowerCap module board has been soldered in place and cleaned, the DS9034PCX PowerCap with Crystal is placed on top of the PCM board to form a complete PowerCap Module package. The PowerCap is keyed to prevent incorrect attachment. Both the DS9034PC/PCI PowerCap and the DS9034PCX PowerCap with Crystal contain a printed circuit board substrate upon which a lithium battery, connectors, and plastic cap are attached. The DS9034PCX also contains a crystal. Based on the description and function of each of these devices, each is a printed circuit assembly that carries out the function of a power supply. You suggested Harmonized Tariff Schedule of the United States of America (HTSUSA) subheading 8473.50.3000, which provides for “Parts and accessories equally suitable for use with machines of two or more of the headings 8469 to 8472: Printed circuit assemblies.” However, although each of these devices is a printed circuit assembly, each is a power supply. Power supplies are provided for eo nominee in heading 8504. Additionally, in a conversation this office held with you, each of these power supplies has numerous uses, which are not limited to use with an automatic data processing (ADP) machine or telecommunications apparatus. As such, they are not dedicated for use solely or principally with automatic data processing (ADP) machines of heading 8471 or for use solely or principally with telecommunications apparatus. Therefore, since the DS9034PC/PCI PowerCap and the DS9034PCX PowerCap with Crystal both perform the function of a power supply, which is provided for in the HTSUSA within heading 8504, they are not parts for machines of two or more headings of 8469 to 8472, specifically ADP machines of heading 8471. Your suggested classification of 8473.50.3000 is inapplicable for these devices.

The applicable subheading for the PowerCap (DS9034PC/PCI) the PowerCap with Crystal (DS9034PCX) will be 8504.40.9540, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Static converters: Other: Rectifiers and rectifying apparatus: Power supplies: Other." The rate of duty will be 1.5 percent ad valorem.


The tariff classification of three power modules from China The merchandise subject to this ruling is three different power modules. They are marketed as power supplies for telecommunication purposes, such as cellular phones, networking equipment, servers and storage applications. Samples of the three types of power modules and datasheets for each sample were submitted. The samples and datasheets identify them as an Austin MegaLynx™ Non-insolated DC-DC power module (ATH030AX3Z), a Power Module DC-DC converter (QBW018A0B1-H), and an Eight-Brick DC-DC converter (EQW025ADY61Z). The Austin MegaLynx™ Non-insolated DC-DC power module (ATH030AX3Z) is utilized for intermediate bus voltage applications, telecommunications equipment, servers and storage applications, and networking equipment. The sample reveals that it will be imported in the form of a printed circuit assembly populated with various discrete active and passive components. This non-isolated DC-DC converter power module is in an industry standard package that can deliver up to 30A of output current with a full load efficiency of 92% to 3.3Vdc output voltage. As a DC-DC converter, it converts direct current of a certain voltage to direct current of another voltage. It operates off an input voltage from 4.5 to 5.5Vdc and provides an output voltage that is programmable from 0.8 to 3.63Vdc. This module has a sequencing feature that enables designers to implement various types of output voltage sequencing when powering multiple modules on the board. Additional features include remote on/off, adjustable output voltage, remote sense, over current, over temperature protection and active current sharing between modules. The Power Module DC-DC converter (QBW018A0B1-H) is utilized for intermediate bus voltage applications, telecommunications equipment, servers and storage applications, and networking equipment. The sample reveals that it will be imported in the form of a printed circuit assembly populated with various discrete active and passive components. This power module is an isolated DC-DC converter that operates over an input voltage range from 36 to 75Vdc and provides a single regulated output. As a DC-DC converter, it converts direct current of a certain voltage to direct current of another voltage. The output is fully isolated from the input, allowing versatile polarity configurations and grounding connections. Built-in filtering for both input and output minimizes the need for external filtering. The QBW018A0B series of DC-DC converters is an expansion of a new generation of DC-DC power modules designed to support 12Vdc intermediate bus applications where multiple low voltages are subsequently generated using discrete/modular point of load (POL) converters. They provide up to 18A output current in an industry standard quarter brick, high current, and 12V intermediate bus voltage applications. The converter incorporates synchronous rectification technology and innovative packaging techniques to achieve ultra high efficiency reaching 93% at 12V full load. This leads to lower power dissipation, such that for many applications a heat sink is not required. The Eight-Brick DC-DC converter (EQW025ADY61Z) is utilized for wireless networks, enterprise networks, and optical and access network equipment. The sample reveals that it will be imported in the form of a printed circuit assembly populated with various discrete active and passive components. The Eight-Brick power module is an isolated DC-DC converter that can deliver up to 25A of output current and provide a precisely regulated output voltage over a wide range of input voltages (Vi = 36-75Vdc). As a DC-DC converter, it converts direct current of a certain voltage to direct current of another voltage. It achieves full load efficiency of 88% at 3.3V output voltage. This converter’s standard features include remote on/off, remote sense, output voltage adjustment, over voltage, over current, and over temperature protection. The Eight-Brick DC-DC converter’s open frame construction enables designers to develop space efficient solutions.

The applicable subheading for the Austin MegaLynx™ Non-insolated DC-DC power module (ATH030AX3Z), the Power Module DC-DC converter (QBW018A0B1-H), and the Eight-Brick DC-DC converter (EQW025ADY61Z) will be 8504.40.8500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical transformers, static converters (for example rectifiers) and inductors; parts thereof: Static converters: For telecommunication apparatus.” The rate of duty will be free.


The tariff classification of the E-Val Pro EVP and Sensor Arrays from Denmark The first item under consideration is identified as the E-Val Pro EVP (Product No. 20160200). When imported, the E-Val Pro EVP will contain a Master Module, ValSuite software, USB cable, LAN cable, 12-volt power supply, sensor array removal tool and carrying case. You state that all of these items are always purchased together under Product No. 20160200. The master module is a general electric device designed for the principle function of data recording and storage. The master module is designed to allow sensors, which measure items such as temperature, pressure, humidity, and carbon dioxide, to be attached. The sensors are always purchased separately and not included with the E-Val Prop EVP. The function of the master module is to receive data from various sensors, record, store, process and display the data, and then transmit the data to a computer for further analysis. The internal memory is capable of holding up to ten studies at a time, and the eight-inch display can display the recorded data. The ValSuite software is the integrated software utilized to run the master module. The USB and LAN cables are used for connectivity. The 12-volt power supply powers the unit. The sensor array removal tool is used for removing the sensor arrays. Finally, the carrying case stores all of the E-Val Pro EVP components. The second item under consideration is identified as a sensor array for use solely with the E-Val Pro EVP. The sensor array is offered in a 4-channel sensor array (Product No. 21600011) and a 12-channel sensor array (Product No. 21600010). Sensor arrays are small aluminum boxes that are attached by screws in the back of the master module. The sensor array receives data from the sensors that are plugged into it, converts the signal, and transmits the data. The sensor array is a proprietary part to the master module and is not suitable for use with any other type of machine. The sensor array could be imported separately or as part of the E-Val Pro EVP package. Based on the information provided, the E-Val Pro EVP meets the definition of a kit. Kits are classified as sets according to the heading of the article or articles that impart the essential character to the set. The Explanatory Notes to the Harmonized Tariff System provide guidance in the interpretation of the Harmonized Commodity Description and Coding System at the international level. Explanatory Note X to General Rule of Interpretation (GRI) 3(b) provides that the term “goods put up in sets for retail sale” means goods that: (a) consist of at least two 2 different articles which are, prima facie, classifiable in different headings; (b) consist of articles put up together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without repacking. Goods classifiable under GRI 3(b) are classified as if they consisted of the material or component which gives them their essential character, which may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the article. GRI 3(c) provides that when goods cannot be classified by reference to GRI 3(a) or 3(b), they are to be classified in the heading that occurs last in numerical order among those which equally merit consideration. It is the opinion of this office that the master controller within the E-Val Pro EVP imparts the essential character, GRI 3(b) noted. Among the kit components, the master controller has the greatest value, greatest weight, and carries out the most essential function. The software, LAN and USB cables, power supply, sensor array removal tool and case all work together to allow the master controller to function as a data recorder. As the primary function of the master controller is that of a data recorder, which displays information about the operating status of the sensors, it meets the definition of a checking instrument. As per HQ H112722 (dated 09/30/10): The tariff term “checking” is not defined by the HTSUS. Relying on the common meaning of the term, the U.S. Court of Customs and Patent Appeals (CCPA) (predecessor to the U.S. Court of Appeals for the Federal Circuit) has defined the term “check” as “to inspect and ascertain the condition of [a thing].” United States v. Corning Glass Works, 66 CCPA 25, 27 (1978) (citing Webster’s Third New International Dictionary 381 (1971)). The CCPA further stated that “checking instruments” clearly and unambiguously encompasses machines that carry out steps in a process for inspecting. In regards to the sensor arrays, Note 2 to Chapter 90 states that: Subject to rule 1 above, parts and accessories for machines, apparatus, instruments or articles of this chapter are to be classified according to the following rules: (a) Parts and accessories which are goods included in any of the headings of this chapter or of chapter 84, 85 or 91 (other than heading 8487, 8548 or 9033) are in all cases to be classified in their respective headings; (b) Other parts and accessories, if suitable for use solely or principally with a particular kind of machine, instrument or apparatus, or with a number of machines, instruments or apparatus of the same heading (including a machine, instrument or apparatus of heading 9010, 9013 or 9031) are to be classified with the machines, instruments or apparatus of that kind; (c) All other parts and accessories are to be classified in heading 9033. By application of Note 2(b) to Chapter 90, parts and accessories included in a heading of Chapter 90 must be classified in that heading. The E-Val Pro EVP, which includes the master module, is classified in heading 9031, Harmonized Tariff Schedule of the United States, (HTSUS). The sensor arrays are proprietary parts to the master module and are thus classified as parts of checking instruments in heading 9031, HTSUS.

The applicable subheading for the E-Val Pro EVP (Product No. 20160200) 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 applicable subheading for the 4-channel sensor array (Product No. 21600011) and 12-channel sensor array (Product No. 21600010), whether or not imported with the E-Val Pro EVP, will be 9031.90.9195, 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: Parts and accessories: Other: Other: Other.” The general rate of duty will be free.


The Protest describes three entries maded on January 29, January 31 and April 13, 2013, and liquidated on June 21, 2013. On June 24, 2016, Protestant provided CBP with a representative sample of the subject module that is not an actual panel retained from the subject entries but, based on the information submitted, is identical in all respects to the panels associated with those entries. The sample consists of two detached junction boxes and one rectangular solar panel labeled, in part, “CanadianSolar, Model Type: CS6P-245P.” The panel measures approximately 1638 mm x 981 mm x 40 mm and is comprised of 60 (6x10) cells. Laboratory analysis of the solar panel indicates that there are three substrings serially connected. Each substring, which is connected in parallel to a diode, contains twenty photovoltaic (PV) cells (in two columns). The panel contains three diodes arranged in a junction box (attached to the rear of the panel) that are used as "bypass" diodes to protect shaded cells from overheating by diverting electrical current around such cells and through an external circuit. The connectors on the panels are designated as "MC4" or "MC4 compatible" and mechanically appear to be only able to connect solar panels with MC4 compatible connectors and not to connect such panels to any other external devices or structures. Below are images of the front and back of the solar panel: ISSUES: Whether the solar module in question is classified (1) under heading 8501, HTSUS, as an electric motor and generator; or (2) under heading 8541, HTSUS, as a photosensitive semiconductor device


The subject merchandise consists of rectangular solar panels of various sizes, as well as foam blocks and plastic tubes in the general form of right prisms. According to Pitsco, all items are designed and marketed for use solely for “educational projects” undertaken by primary and secondary school students in settings like classrooms, science fairs, and science competitions. Pitsco asserts that when used in conjunction with complementary components, as well as instructional materials, the merchandise effectively promotes understanding of science, technology, engineering, and mathematics (i.e., “STEM”) principles. The solar panels are of three types - designated “Panel 1”, “Panel 2”, and “Ray Catcher” - all of which consist of solar cells mounted on a plastic frame or base (See Figures 1, 2, and 3 below). All three solar panel types include electrical wires, which, in the cases of Panel 1 and Panel 2, are capped with electrical alligator clamps. Figure 1 (Panel 1) Figure 2 (Panel 2) Figure 3 (Ray Catcher) Each panel is of unique dimensions and energy output capacity, which are summarized in the following chart excerpted from Pitsco's internal advice request: According to Pitsco, the solar panels are designed for use, and are actually used, exclusively in projects undertaken in classrooms and similar academic environments, the objective of which is to impart an understanding of solar energy principles. Projects in which the solar panels are ostensibly used include, among others, those entailing the construction of miniature solar-powered cars (see Figure 5 below). The tube is hollow, open-ended, and composed of lightweight, malleable plastic (see Figure 4 below). Running the length of its bottom side is an indent that imparts the tube's aperture with a general “U” shape. The tube's top side incorporates a separate rectangular opening approximately 1 ¼ inches from its back end. Pitsco asserts that the plastic tube's unique size, shape, and composition render it suitable for use only in educational projects involving the construction of miniature solar-powered cars, an example of which is depicted in Figure 5 below. The ostensible objective of such projects is to advance students' understanding of STEM principles like modeling, aerodynamics, friction, calculating speed, and Newton's laws of motion. Pitsco also states that the tube is packaged for retail sale to educators in kits containing other project components, including the aforementioned Panel 1 or Panel 2, a motor, gear font, wheels, axles, and washers, as well as an instructional guide. Figure 4 Figure 5 The block is composed of high-density foam and incorporates along its bottom side a continuous indent similar to, albeit narrower than, that of the tube (see Figure 6 below). Its back end contains a pre-drilled 2-inch hole, which, according to Pitsco, is designed to accommodate a carbon dioxide-filled cartridge. As with the plastic tube, Pitsco asserts that the block's unique size, shape, and composition render it suitable for use only in student construction of a miniature CO2-powered “F1” car, the purpose of which is to promote STEM principles like, for example, the scientific method, acceleration, reaction time, and surface area calculation. Pitsco also states that the tube is packaged for retail sale to educators in kits containing other solar-powered car components, including a CO2 cartridge, wheels, axles, sandpaper, screw eyes, washers, and a wooden “blank” with a form and dimensions identical to those of the subject foam block (see Figure 7 below). Figure 6 Figure 7 The solar panels were entered in heading 8541, HTSUS, the foam block was entered in heading 3909, HTSUS, and the plastic tube was entered in heading 3926, HTSUS. Pitsco claims that all merchandise at issue is properly classified in heading 9023, HTSUS.


The tariff classification of a Digital Tuner and Metronome from China Pictures and descriptive literature were provided for our review. The item under consideration is identified as the Taylor Beacon (part number K0502001000002), which is a digital clip-on 5-way tuner/metronome that contains a tuner, metronome, timer, countdown clock and flashlight. The item features a thin film transistor (TFT) LCD screen, selectable CGBVU tuning modes (chromatic, guitar, bass, violin, ukulele) for tuning other instruments, and 12 preset time signatures for the metronome. The tuner is designed to detect vibrations of the sounds produced by the instrument strings, compare the vibrations to a standard and display the variance on the screen. The timer and countdown timer allow for tracking the time of sessions. The flashlight is located on the back of the device and is utilized to illuminate sheet music in low light. The unit is rechargeable with a provided USB cable. The subject Taylor Beacon is considered a composite machine that performs a tuning function, a metronome pace of play function, timer and countdown functions, and an illumination function via the flashlight. As Section 16 Note 3 instructs, where a composite machine performs two or more functions it is to be classified in accordance with its principal function. We are of the opinion that the principal function of the subject Taylor Beacon is the tuning function. While the remaining functions are important, the primary reason a user would purchase this device is the ability to tune their instruments. Accordingly, as you suggest in your letter, the applicable subheading for the Taylor Beacon (part number K0502001000002) will be 9031.80.8085, Harmonized Tariff Schedule of the United States (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. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9031.80.8085, 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., 9903.88.01, in addition to subheading 9031.80.8085, 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 https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions 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 at https://hts.usitc.gov/current. 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 jason.m.christie@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division


The tariff classification and country of origin of the SenseHub Tag In your letter dated October 6, 2023, you requested a tariff classification and country of origin determination ruling.   The item under consideration is described as the “SenseHub Tag” or “Tag,” which is a device designed to monitor a cow’s behavior through a proprietary algorithm that provides the farmer, via the Tag’s software, the necessary information about changes in behavior to make informed farm management decisions.  This monitoring is achieved through two sensors (a temperature sensor and a MEMS accelerometer) and an infrared (IR) receiver within the Tags. The temperature sensor updates the Tag with an ambient temperature (i.e., air temperature, not the cow’s body temperature) measurement, which is used for monitoring general environmental conditions. The MEMS accelerometer gathers information on the dairy cow’s activity by sensing velocity, force, vibration (measured in three axes), and acceleration. This information is then processed and transmitted through the overall system, and used to assess the animal’s behavioral state once it reaches the cloud or farmer. Finally, the IR receiver communicates with IR transmitters located at different parts of the farm (e.g., at sorting gates) and receives a unique IR signal from the IR transmitter (2.4 GHz - 802.15.4 Zigbee protocol wireless communication hardware) identifying the Tag’s location. Once the receiver receives the location data, the Tag’s CPU aggregates this location data with other data collected by the Tag. The Tag then processes and transmits the location data in real-time back out of the Tag, specifically, to the Controller, and then to the cloud or farmer. The Tag additionally contains a central processing unit (CPU) which aggregates and filters the data from the MEMS sensor and contains a short-term memory cache for storing most data for up to 20 minutes. The transmission of data permits the overall system to know the cow’s location and (as needed) open gates or enable milking machines for the cow wearing the particular Tag. A user, on their smart device, can then view a range of reports and graphs, including ones that show how rumen activity for any specific cow wearing the Tag is affected by feeding changes, typical physiological phases (e.g., calving, lactation starting), etc. The SenseHub Tags will be imported with a belt, belt rings, full rubber weight, and installation instructions. The belt and belt rings allow the Tag to be placed around the neck of the dairy cow. The weight provides a counterbalance to the Tag to ensure the Tag falls on the cow’s neck at the best position for the wireless receipt and transmission of data. The installation instructions are provided to assist the farmer in installing the Tag around the dairy cow’s neck. The SenseHub Controller will be imported separately. Classification under the Harmonized Tariff Schedule of the United States (HTSUS), is made in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings and any relevant section or chapter notes. In the event the articles cannot be classified solely on the basis of GRI 1, GRI’s 2 through 6 may be applied in order, as appropriate. The Explanatory Notes to the HTSUS, while not legally binding, may also be consulted to aid in classification. The Tag is considered to be a composite good within the meaning of GRI 3. Goods classifiable under GRI 3(b) shall be classified as if they consisted of the material or a component which gives them their essential character. The Explanatory Note to GRI 3(b)(VIII), states that the factors which determine essential character will vary between different kinds of goods. It may for example, be determined by the nature of the materials or components, its bulk, quantity, weight, or value, or by the role of a constituent material in relation to the use of the goods. GRI 3(c) states that when the essential character of a composite good cannot be determined, classification is based on the heading that occurs last in numerical order among those which equally merit consideration. In your letter, you suggest the applicable subheading for the SenseHub Tag to be 8517.62.0090, HTSUS. We disagree. The item is used to determine or track the activity/location of cows. It’s a monitoring device that determines the level of physical movement/exertion. The location and activity functions are carried out by various sensors. Without the ability to identify the cow’s location and/or be able to measure the movement of the cow, there would be no need for the transmission function. In other words, the transmission of data is in service of determining a cow’s location and physical activity. It is the opinion of this office that the wireless transmission ability in heading 8517, HTSUS, merits equal consideration to the accelerometer in heading 9031, HTSUS. Consequently, classification will be determined based on the competing heading that occurs last in numerical order. Therefore, according to GRI 3(c), the applicable subheading for the SenseHub Tag 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. 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/current. Regarding the country of origin of the SenseHub Tag, the manufacturing will occur in Mexico from nine subassemblies or components originating in Mexico, Switzerland, and China. The two main subassemblies of the product are a weather-sealed plastic housing (with cover, body, and belt rings) and a printed circuit board assembly (PCBA) contained within the housing. The product’s PCBA will be assembled in Mexico, with surface-mount technology (SMT) equipment used to build up a bare printed circuit board (PCB) into a finished PCBA. Through SMT, numerous individual components will be soldered onto the bare printed circuit board to create a functional motherboard PCBA specifically designed for the Tag. At the facility in Mexico, 49 different components (including both the primary functional components discussed above such as the MEMS accelerometer, as well as secondary components such as ceramic capacitors and resistors, among other components) from numerous different countries (including the Philippines, Singapore, Taiwan, Thailand, the Czech Republic, Israel, and China) will all be surface mounted to form the finished PCBA. After physical assembly of the PCBA in Mexico, the PCBA will also be programmed in Mexico (using software developed in Israel) and tested in Mexico. This programmed PCBA becomes the “brain” of the Tag. Once the PCBA is completed in Mexico, within the same production facility it will be incorporated into the plastic housing of the final article with components from Switzerland, China, and Mexico. The product’s cover, body, and belt rings will be injection molded in Mexico from plastic raw material sourced from Switzerland. The cover will be made of IR-transparent plastic that filters incoming IR signals from IR transmitters external to the Tag and permits those signals to be received by the IR receiver on the PCBA under the cover. An NFC antenna, belt, and full rubber weight sourced from China are also added as part of the device assembly in Mexico. The belt attached to the housing serves to place the Tag around the cow’s neck, while the weight hangs from the bottom of the belt to ensure that the Tag always remains in the correct location on the left side of the cow’s neck. Additional shock absorbers within the device will also be sourced from Mexico. During the prod


The tariff classification of a sensor module from Japan Descriptive literature was provided for our review. The item under consideration is described as the 5Q-SSM sensor module, which is a Quartz Crystal Microbalance (QCM)-type smell sensor that detects changes in mass due to the adsorption/desorption of odor molecules onto a membrane surface. These changes are translated into resonance frequency shifts (in Hz) of the quartz crystal unit and output as digital data. The sensor can be embedded into other articles or used as a standalone device. The 5Q-SSM measures 20mm by 28mm by 2.84mm and weighs 10g. It is imported with the sensor (including 5 membranes with different chemical affinity), a USB converter board, an optional protective case, a USB flash drive with software, and a micro-USB cable. The sensor module includes a set of five standardized membranes designed for general odor identification (such as ethanol, toluene, kerosene, etc.). Custom sets tailored for specific applications are also available. The sensor is used for proof-of-concept (POC) evaluation and may be embedded in broader systems or consumer devices for smell detection. The device is intended for Internet of Things (IoT) home monitoring devices (e.g., wall outlets that detect odors), smart agriculture (e.g., detecting gas emissions from crops), odor detection systems in industrial or consumer use, environmental and ambient monitoring, quality control, and healthcare.

The applicable subheading for the 5Q-SSM sensor will be 9031.80.8085, Harmonized Tariff Schedule of the United States (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. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 9031.80.8085, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance.


The tariff classification, country of origin, and eligibility under the United States-Mexico-Canada Agreement (USMCA) of a dynamometer In your letter dated January 20, 2026, you requested a ruling on the tariff classification, country of origin for marking purposes, and USMCA eligibility of a dynamometer. The item under consideration is an electric motor dynamometer, which is a specialized testing apparatus designed for the development and evaluation of e-bike mid-drive units (motor, gearbox, and motor controller assembly). The device simulates the forces and resistances encountered during actual riding to enable engineers to assess performance characteristics without extensive road testing. This system is precisely configured with two internal permanent magnet test motors, each coupled to planetary gearboxes. These gearboxes are connected via flexible shaft couplings to two torque transducers, which in turn attach to the device under test (DUT), an e-bike mid-drive unit. One motor replicates human pedaling input, while the second motor provides the load, mimicking hills or headwinds. All components are mounted on a shared extruded aluminum base, secured to a table, and are controlled by dedicated motor controllers (inverters) that manage speed and torque. The motors and DUT share a common electrical connection for power sharing, supplied by a single power supply and protected by fuses and contactors. Additional fans provide cooling for the DUT and motors, and a polycarbonate cover ensures safety over the DUT. The DUT is supported by custom aluminum blocks and bearing housings, with the dynamometer arriving pre-assembled and bolted together for completion upon import. Integrated sensors measure crucial parameters such as torque output, motor speed, power consumption, and efficiency, allowing manufacturers to refine motor design, optimize control algorithms, and verify that the mid-drive unit meets performance and durability standards. Sensors include thermocouples, torque transducers (strain gauges), rotational speed sensors (encoders), voltage sensing (precision resistor divider), and a current sensor (hall-effect based non-contact sensor). Additional internal sensors exist in the motor (resolver, thermistor) and the controller (hall-effect based non-contact sensor, thermistor). The device will measure torque in Newton-Meters (Nm), rotational speed in Rotations Per Minutes (RPM), temperature in degrees Celsius, power in Watts (W), voltage in volts (V), and current in Amps (A). The electric motor dynamometer is a product of extensive global collaboration, with its components sourced from a diverse range of countries including China, the United States, India, Sweden, Canada, Taiwan, Japan, South Korea, Italy, Malaysia, Germany, Mexico, Austria, Hungary, Belgium, France, the Philippines, Poland, and Switzerland. Key components originating from China include transducers, the planetary gearbox, table, DUT holder block, bearing holders, fasteners such as nuts and bolts, the DUT output shaft, power supply, a 50A contactor, fuses, connectors, crimps and crimp tools, and the breakout board. The United States contributes essential parts like spiders for couplings, shaft couplings, 10 mm keys, raw material for the polycarbonate enclosure, nylon strapping, bolts, protection guard doublers, polycarbonate adhesive, fasteners, L brackets, washers, vibration dampers, a board, and a portion of the wiring. Taiwan supplies nuts, bolts, the E-stop button, inverter fans, motor fans, the resistor divider, and various wiring harnesses. India is the source for the Data Acquisition (DAQ) expander and the motors themselves. Germany provides aluminum extrusion, relays, splices, and capacitors, while Canada supplies foam insulation. Italy contributes bolts, and bearings are sourced from either Japan or South Korea. The motor controller is procured from Sweden. Malaysia supplies the amplifier, plugs, receptacles, and crimps. Mexico provides bars, resistors, shunts, and connectors. Additionally, various other small components are sourced from Japan, Belgium, France, the Philippines, Poland, and Switzerland. The dynamometer assembly process, conducted in Canada, comprises approximately twenty-six distinct steps. It commences with the connection of the gearbox and motors to the drive shaft using nuts and bolts, followed by the assembly of the Device Under Test (DUT) enclosure. Subsequently, torque transducers are secured, holes are drilled into the prep support table, and the bearing support is fabricated by pressing the bearing and datum pin into place. The DUT output shaft is then installed onto its support, datum pins are pressed into the DUT holder block, and the DUT support block is affixed to the dynamometer base plate. The process continues with the assembly of the bearing support to the DUT support, the installation of keys onto the DUT output shafts, and the attachment of the coupling to the DUT output shafts. Two keys are then installed onto the torque transducer before it is mounted to the gearbox coupling. Next, the motor and gearbox assembly is integrated by sliding it into the extruded base and securing it with fasteners. This is followed by mounting the motor controllers for heatsinking and the precise cutting and crimping of terminals and wires. The fan is then installed onto the DUT enclosure, which is subsequently mounted onto the base. The final stages involve the installation of the high-current bus distribution bar, fastening the entire assembly to the table with bolts, installing the power supply and DAQ system, and completing the wire harness assembly and routing to achieve full functionality. In your letter, you suggest the applicable subheading of the electric motor dynamometer to be 9031.80.8070, Harmonized Tariff Schedule of the United States (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: Equipment for testing the characteristics of internal combustion engines: Other.” We disagree. Since the device that is to be tested by the dynamometer is a mid-drive electric motor and not an internal combustion engine, classification under subheading 9031.80.8070, HTSUS, is excluded. Accordingly, the applicable subheading for the electric motor dynamometer 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. COUNTRY OF ORIGIN Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a subst


The tariff classification and country of origin of an Industrial Data Acquisition Sensor Box In your letter dated March 23, 2026, you requested a tariff classification and country of origin determination ruling. Descriptive literature was provided for our review. The subject merchandise is an Industrial Data Acquisition Sensor Box designed for monitoring electrical parameters of industrial machinery. The device obtains current and voltage from connected industrial machines, processes the data, and transmits digital data via WiFi, USB, or Ethernet connection. The unit is Bluetooth enabled for wireless configuration and adjustments. The sensor is housed in a CNC-machined aluminum enclosure, which is designed for indoor use in controlled environments. We find the Industrial Data Acquisition Sensor Box to be similar to the DAQ-800 discussed in New York Ruling N301112 (dated October 30, 2018). In the ruling it states: Based on the information provided, the DAQ-800 performs no measurements or analyses itself, nor does it serve to control any of the plant equipment to which it is connected. Instead, the DAQ-800 receives the analog signals that the measurement equipment in the plant equipment transmits and converts it to digital data that can be displayed by the Shotscope program. In this respect, the DAQ-800 serves a function similar to that of the data recorders described in Headquarters Ruling Letter (HRL) H112722 (dated September 30, 2010). The data recorders in that ruling received electrical signals from sensors incorporated into industrial machinery and translated said signals into readable data that provided information on the operating status of the equipment. HRL H112722 found that the data recorders served as checking instruments of heading 9031, and classified them accordingly. The Industrial Data Acquisition Sensor Box is constructed with components from China, France, the U.S.A., Mexico, the United Kingdom, Canada, Taiwan, and the Philippines. The Chinese components include the printed circuit board (PCB), the ESP32 module, power supply, rocker switch, wire, USB connector, housing, bottom and top caps, and magnet. The French components include the banana jack sensor cables. The ring connector, hex nut, and tapered heat-set plastic insert are of U.S.-origin. The female quick connect is from Mexico, the USB-A adapter is from the United Kingdom, and the screws are from Taiwan and the Philippines. The complete assembly process occurs in Canada along with the creation and flashing of the firmware. The assembly process begins with preparing the Chinese-origin enclosure, a black anodized aluminum heatsink body featuring cooling fins on all four sides. This enclosure is placed on an anti-static mat with its open cavity facing upward, its interior is inspected, and then cleaned for any debris. The four corner mounting holes for the lid screws and the input/output (I/O) panel cutout on the front face are confirmed to be clear and ready. Subsequently, the I/O panel, which serves as the front-facing aluminum plate for external connectors is fitted with its components. This includes installing a rocker power switch, a USB Type-A port, and two pairs of red and black banana jacks into their respective cutouts and holes, securing them with screws and ensuring correct orientation. The RECOM AC-DC power supply module is then mounted inside the enclosure body, adjacent to the I/O panel, with its AC input accessible and DC output terminals ready for wiring. Following the initial component installations, the PCB sub-assembly is prepared by mounting the pre-assembled PCB, which includes an ESP32 module, onto the underside of the top lid plate using brass standoffs. This assembly is secured with screws in a cross pattern to ensure even seating. The power circuit is then wired, connecting the RED wire from the RECOM module to the rocker power switch and then to the PCB’s positive terminal, while the BLACK wire connects directly to the PCB’s negative terminal. A chassis ground wire is also connected from the RECOM module to the enclosure chassis for safety. The banana jacks are wired to the corresponding Voltage and Current terminal blocks on the PCB, and the USB cable is routed from the panel-mount port to the ESP32 module. After all wiring is completed and verified, including insulating the banana jack terminals with liquid electrical tape to prevent shorting, a final comprehensive check of all connections is performed before the lid is attached. The lid, with the PCB assembly facing downward, is carefully lowered and secured with screws from the bottom of the enclosure. Finally, the I/O panel, with all its connectors installed and wiring routed correctly, is aligned and secured to the front of the enclosure. The printed circuit board assembly (PCBA) incorporated within the device is a custom-designed printed circuit board assembly fabricated in Canada. The board is designed around an ESP32-DEVKITC-32E microcontroller module and two ADS8864 analog-to-digital converters (ADCs). Its primary function is to receive analog electrical signals from external sensors connected to the device, condition and digitize those signals, perform onboard data preprocessing, and transmit the resulting data to an external server or computer for further analysis. CLASSIFICATION As suggested in your letter, which also aligns with ruling N301112, the applicable subheading for the Industrial Data Acquisition Sensor Box will be 9031.80.8085, Harmonized Tariff Schedule of the United States (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 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/. ORIGIN In regard to marking, section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in sections 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect to goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determining the country of origin of a good for marking purposes, with the exception of textile and apparel goods which are s


Зарядно устройство за мобилен телефон. Електрическите параметри при изхода на устройството са в границите на 150-500 mAh и 3.8 V.

FOR TELECOMMUNICATIONS
STATIC CONVERTERS

Общи правила 1 и 6 за тълкуване на Комбинираната номнклатура, текстовете на КН кодове 8504, 8504 40 и 8504 40 30.


Dle údajů žadatele se jedná o procesory (integrované obvody) určené k vestavění do elektronické řídící jednotky. Popis výrobku: Monolitický integrovaný obvod, v němž jsou jednotlivé prvky obvodu vytvořeny ve hmotě a na povrchu polovodičového materiálu a jsou spolu neoddělitelně spojeny. Funkce: Aktivní elektronická součástka - integrovaný obvod. Osazuje se na řídící desku. Procesor je naprogramovaný k vykonávání specifických funkcí na řídící desce. Rozměry: 18 x 18 x 2,5 mm.

CONTROLLERS
ELECTRONIC
FOR BUILDING-IN
IN A HOUSING
INTEGRATED CIRCUITS
MONOLITHIC INTEGRATED CIRCUITS
ONE-PIECE
PROCESSORS

Všeobecná pravidla 1 a 6 pro výklad kombinované nomenklatury. Poznámka 8 b) 1) ke kapitole 85. Vysvětlivky k HS k číslu 8542. Vysvětlivky ke KN k podpoložkám 8542 31 10 a 8542 31 90. Znění kódů 8542, 8542 31 a 8542 31 90 KN.