CLA-2 CO:R:C:M 950440 MBR

8517.40.50

Mr. Gordon W. Larson
Rudolph Miles & Sons
4950 Gateway East
P.O. Box 144
El Paso, Texas 79942

RE: Home Alarm Systems; Components Shipped in Bulk Form; Control Panel Printed Circuit Boards; Home Security Panels; 300 MHz Radio Frequency Transmitters and Receivers; Telephonic Dialer Boards; Infrared Detectors Incorporating RF Transmitters; Parts

Dear Mr. Larson:

This is in reply to your letter of October 1, 1991, requesting classification of home alarm system components imported from Mexico, on behalf of Honeywell Protective Services Division, under the Harmonized Tariff Schedule of the United States (HTSUS).

FACTS:

Presently, you import the following home alarm system components from Mexico:

-Control panel boards for systems 1500, 1500e MOD II, 2000e, and 6000 (future system).

-Alphanumeric home security panel and security panels for system 1500, 1500e MOD II, 2000, and 6000.

-300 MHz Receiver.

-300 MHz Transmitters, models TH8802, and T8803.

-System 1500 dialer board.

-2-

-Hardwire expander boards, hardwire module boards, multiple receiver adapter boards, receiver interface boards, remote receiver adapter boards, PLC boards, alphanumeric HSP adapter boards, and end of line module boards.

ISSUE:

What are the classifications of home alarm system components, under the Harmonized Tariff Schedule of the United States (HTSUS)?

LAW AND ANALYSIS:

The General Rules of Interpretation (GRI's) to the HTSUS govern the classification of goods in the tariff schedule. GRI 1 states, in pertinent part:

...classification shall be determined according to the terms of the headings and any relative section or chapter notes....

HQ 088891, dated June 21, 1991, determined that bulk shipments of the instant merchandise "would not be considered to have the essential character of a complete home alarm system, because they are apparently nothing more than disparate components shipped in bulk form." Furthermore, HQ 088891 held that "[i]f the 'upgrade kits' (consisting of up to 8 Alphanumeric HSPs and Alphanumeric Adapter Boards) are goods put up in sets for retail sale, they are determined to have the essential character of the Alphanumeric HSPs."

HQ 088595, I/A 4/91, dated September 12, 1991, held that a "control panel" printed circuit board without the keypad, was classifiable under subheading 8531.90.00, HTSUS, which provides for: "[e]lectrical sound or visual signaling apparatus (for example, bells, sirens, indicator panels, burglar or fire alarms), other than those of heading 8512 or 8530; parts thereof: [p]arts." Therefore, the control panel boards for systems 1500, 1500e MOD II, 2000e, and 6000 are similarly classifiable under subheading 8531.90.00, HTSUS.

The "Home Security Panel" (HSP) consists of a digital key, a sounding device for audible alarms, a point identification display, six touch switches, and 12 indicator lights. HQ 087876, dated December 27, 1991, held that "Indicator Panel/Keypad Units" for home alarm systems were classifiable under subheading 8531.20.00, HTSUS, which provides for: "[e]lectrical sound or visual signaling apparatus (for example, bells, sirens, indicator panels, burglar or fire alarms), other than those of heading 8512 or 8530; parts thereof: [i]ndicator panels incorporating liquid crystal devices (LCD's) or light emitting diodes (LED's)." Therefore, the "alphanumeric home security panel" and security panels for the

-3-

1500, 1500e MOD II, 2000, and 6000 systems, are similarly classifiable in subheading 8531.20.00. HTSUS.

The 300 MHz radio frequency transmitters (models TH8802, and T8803) transmit data regarding the occurrence of events such as the opening or closing of a circuit (window/door detector) or a panic button signal. Pursuant to Section XVI, Legal Note 2(a), regarding parts, such transmission apparatus for radio broadcasting is classifiable in subheading 8525.10.80, HTSUS, which provides for: "[t]ransmission apparatus for...radiobroadcasting...: [o]ther: [t]ransmitters."

The infrared detectors, incorporating RF transmitters, are composite machines. The principal function is determined to be that of detection for an alarm system. Therefore, pusuant to Section XVI, Legal Note 3., the infrared detectors incorporating RF transmitters are classifiable in subheading 8531.90.00, HTSUS.

The 300 MHz radio frequency receiver is used to receive signals from transmitters and relay the signal to the control panel for processing. Pursuant to Section XVI, Legal Note 2(a), regarding parts, such radio frequency receivers are classifiable in subheading 8527.39.00, HTSUS, which provides for: "[r]eception apparatus for...radiobroadcasting...: [o]ther radiobroadcast receivers...: [o]ther."

The optional system 1500 dialer board utilizes telephone lines to dial up and signal a remote Customer Service Center. Pursuant to Section XVI, Legal Note 2(a), regarding parts, such telephonic apparatus is classifiable in subheading 8517.40.50, HTSUS, which provides for: "[e]lectrical apparatus for line telephony or telegraphy, including such apparatus for carrier-current line systems; parts thereof: [o]ther apparatus, for carrier-current line systems: [o]ther: [t]elephonic."

The hardwire expander boards, hardwire module boards, multiple receiver adapter boards, receiver interface boards, remote receiver adapter boards, PLC boards, alphanumeric HSP adapter boards, and end of line module boards, are all parts of the alarm system, and pursuant to Section XVI, Legal Note 2.(b), are classifiable in subheading 8531.90.00, HTSUS, which provides for: "[e]lectrical sound or visual signaling apparatus (for example, bells, sirens, indicator panels, burglar or fire alarms), other than those of heading 8512 or 8530; parts thereof: [p]arts."

HOLDING:

The control panel boards for systems 1500, 1500e MOD II, 2000e, and 6000 are classifiable under subheading 8531.90.00, HTSUS.

-4-

The "Home Security Panels" (HSPs) are classifiable under subheading 8531.20.00, HTSUS.

The 300 MHz radio frequency transmitters (models TH8802, and T8803) are classifiable in subheading 8525.10.80, HTSUS.

The infrared detectors incorporating transmitters are classifiable in subheading 8531.90.00, HTSUS.

The 300 MHz radio frequency receivers are classifiable in subheading 8527.39.00, HTSUS.

The system 1500 dialer boards are classifiable in subheading 8517.40.50, HTSUS.

The hardwire expander boards, hardwire module boards, multiple receiver adapter boards, receiver interface boards, remote receiver adapter boards, PLC boards, alphanumeric HSP adapter boards, and end of line module boards, are classifiable in subheading 8531.90.00, HTSUS.

Sincerely,

John Durant, Director
Commercial Rulings Division