OT:RR:CTF:EMAIN H328693 MFT
Center Director
Electronics Center of Excellence and Expertise
U.S. Customs and Border Protection
301 E. Ocean Blvd., Suite 1400
Long Beach, CA 90802
Attn: Gregory Dailey, Import Specialist
Re: Request for Internal Advice on the Tariff Classification of a USB Docking Station
Dear Center Director:
This letter is in response to a request for internal advice concerning the proper
classification under the Harmonized Tariff Schedule of the United States (HTSUS) of a certain
USB docking station. The request was filed by counsel on behalf of Bizlink Technology, Inc.
(requestor). This ruling takes into account the substance of our discussion with counsel to the
requestor, held on August 14, 2025, as well as the supplemental submission provided by counsel
immediately following our discussion.
FACTS:
The subject merchandise is a Dell D3100 “Dockport” USB docking station (“D3100” or
“docking station”). Through a single connection, the docking station allows users to connect to
the Internet, external devices, and up to three additional monitors. The D3100 features one USB
3.0 Type-B port for upstream input, and the following downstream outputs:
• three USB 3.0 ports;
• two USB 2.0 ports;
• two HDMI ports;
• one DisplayPort;
• one RJ45 Gigabit Ethernet port;
• one combination audio port for a headphone and microphone; and
• one audio line out.
The D3100 also includes a two-foot USB 3.0 I/O cable, a power adapter and power cord,
and an HDMI-to-DVI adapter. The D3100 measures 166 mm x 76 mm x 29 mm and weighs 0.43
lbs.
On August 25, 2021, the requestor sought internal advice from CBP concerning the
classification of the subject docking station. The requestor does not dispute that the docking
station is prima facie classifiable as a unit of an ADP machine of heading 8471, HTSUS.
However, the requestor argues that CBP must classify the D3100 under heading 8517, HTSUS,
pursuant to General Rule of Interpretation (GRI) 1 (Note 3 to Section XVI, HTSUS) and GRI
3(c).
ISSUE:
Whether the subject docking station is classified under heading 8471, HTSUS, as a unit
of an ADP machine, or under 8517, HTSUS, as an apparatus for the transmission or reception of
voice, images, or other data.
LAW AND ANALYSIS:
Classification under the HTSUS is in accordance with the GRIs. GRI 1 provides that the
classification of goods will be determined according to the terms of the headings of the tariff
schedule and any relative section or chapter notes. In the event that the goods cannot be
classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise
require, the remaining GRIs 2 through 6 will then be applied in order.
The HTSUS headings under consideration are as follows:
8471 Automatic data processing machines and units thereof; magnetic or
optical readers, machines for transcribing data onto data media in
coded form and machines for processing such data, not elsewhere
specified or included:
*****
8517 Telephone sets, including smartphones and other telephones for
cellular networks or for other wireless networks; 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 than
transmission or reception apparatus of heading 8443, 8525, 8527 or
8528; parts thereof:
Note 3 to Section XVI, HTSUS, provides as follows:
Unless the context otherwise requires, composite machines consisting of two or
more machines fitted together to form a whole and other machines designed for the
2
purpose of performing two or more complementary or alternative functions are to
be classified as if consisting only of that component or as being that machine which
performs the principal function.
The subject docking station constitutes a composite machine that consists of several
downstream outputs which can perform complementary functions simultaneously. In particular,
the several USB ports allow for an ADP machine to connect to various peripheral devices; the
HDMI and DisplayPort outputs allow users to display images to multiple monitors; the RJ-45
Gigabit Ethernet port allows for Internet connectivity; and the audio ports allow for users to
connect the ADP machine to microphones, headphones, speakers, and other audio devices.
Because the docking station can perform several complementary functions, GRI 1 (Note 3 to
Section XVI, HTSUS) requires that the docking station be classified as if consisting of the
component – or as being the machine – which performs the principal function. The requestor
argues that we cannot determine the principal function of the D3100 because heading 8471,
HTSUS, and heading 8517, HTSUS, equally apply. We disagree.
In this respect, we initially note that CBP has previously considered the classification of
docking stations similar to the subject merchandise. For example, in Headquarters Ruling Letter
(HQ) H337673, CBP reviewed certain docking stations that “include[d] two USB 3.0 ports,
audio in and out ports, four USB 2.0 ports, display ports, a host port, a power button, and a high-
speed Gigabit Ethernet port for network connection” to determine whether the merchandise
could be classified under heading 8471, HTSUS, or heading 8517, HTSUS. 1 We found that the
docking stations “enhance[d] the functionality of an ADP machine by providing various
downstream outputs,” and that “[t]his function is described under heading 8471, HTSUS,” which
includes “units” of ADP machines. 2 Further, we rejected the protestant’s assertions that the
merchandise could be classifiable under heading 8517, HTSUS, because out of all the ports on
the device, the Ethernet port was the sole connector that was “primarily for the transmission or
reception of data from one ADP machine to another.” 3 We thus found that the docking stations
principally functioned as “units” of ADP machines under heading 8471, HTSUS.
Similarly, in New York Ruling Letter (NY) N307285, CBP reviewed four docking
stations from China, each bearing the principal function of allowing users to connect an ADP
machine to multiple display monitors, the Internet, and several peripherals “through a single
USB input connection.” 4 For example, one of the models in that decision “[was] described as a
plastic enclosure having two HDMI ports, two DisplayPorts, audio lines in/out, one RJ45
Ethernet Port, six USB 3.0 Ports, and a single USB-C port.” That decision held that the docking
stations were properly classified under heading 8471, HTSUS, specifically as control or adapter
units of ADP machines.
Just like the merchandise discussed in HQ H337673 and NY N307285, the principal
function of the subject docking station is to allow users to connect an ADP machine to multiple
1
See HQ H337673 (May 20, 2025).
2
Id.
3
Id.
4
See NY N307285 (Nov. 22, 2019).
3
display monitors, the Internet, and several peripherals “through a single USB input connection.” 5
The D3100 augments the functionality of an ADP machine by providing various downstream
outputs. This function is described under heading 8471, HTSUS, which provides for units of
ADP machines. As such, the docking station is properly classified under heading 8471, HTSUS,
based on its principal function of acting as a unit to an ADP machine. Heading 8517, HTSUS,
does not describe the docking station’s principal function. That heading applies to articles whose
principal function is to act as an “apparatus for the transmission or reception of voice, images or
other data” (emphasis added). Like the merchandise at issue in HQ H337673, and apart from the
RJ-45 Ethernet port, none of the downstream outputs here are primarily for the transmission or
reception of data from one ADP machine to another. Instead, the outputs are for connecting an
ADP machine to display monitors, headphones, microphones, and other peripherals.
Based on the subject merchandise’s functionality, we find that the Dell D3100 Dockport
USB docking station is properly classified in accordance with its principal function under
heading 8471, HTSUS, as a unit to an ADP machine.
HOLDING:
By application of GRIs 1 (Note 3 to Section XVI, HTSUS) and 6, the subject USB
docking station is classified under heading 8471, HTSUS, specifically subheading 8471.80.10,
HTSUS, which provides for, “Automatic data processing machines and units thereof; magnetic
or optical readers, machines for transcribing data onto data media in coded form and machines
for processing such data, not elsewhere specified or included: Other units of automatic data
processing machines: Control or adapter units.” The general, column one rate of duty is free.
This ruling does not address the applicability of any additional duties that may apply to
the goods discussed herein. Likewise, 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://www.usitc.gov.
You are to provide this decision to the requestor no later than 60 days from the date of the
decision. At that time, the Office of Trade, Regulations and Rulings will make the decision
available to CBP personnel and to the public on the Customs Rulings Online Search System
(“CROSS”), at https://rulings.cbp.gov/, and other methods of public distribution.
Sincerely,
for Yuliya A. Gulis, Director
Commercial and Trade Facilitation Division
5
See id.
4