OT:RR:CTF:TCM H356461 TPB
Cusan Customs Service Inc.
Attn: KIM Jeong-Eun
#309, 35, Magokjungang 2-ro
Gangseo-gu, Seoul
Republic of Korea
Re: Tariff classification of an indoor exercise platform utilizing augmented reality (AR)
technology
Dear Kim Jeong-Eun:
This in response to your eRuling request, dated May 26, 2025, in which you
requested a prospective binding tariff classification ruling from U.S. Customs and
Border Protection (CBP) on behalf of Twohands Interactive Inc. (Twohands /
Requestor). Your ruling request, which was forwarded to our office for a response,
concerns the tariff classification of an indoor exercise platform utilizing augmented
reality (AR) technology, under the Harmonized Tariff Schedule of the United States
(HTSUS).
FACTS:
The merchandise at issue is described as the DIDIM Kiosk (DIDIM), model
number DIDIM-KA19PL, an augmented reality indoor exercise platform that
incorporates non-contact LiDAR (Light Detection and Ranging) sensing technology.
The DIDIM measures 5’4” tall, 19” wide and 16” deep, weighs 117 pounds, and is
equipped with a projector, sensor, and PC (personal computer) that provides an AR
indoor exercise platform using 3D spatial analysis sensing technology incorporating
non-contact 3D LiDAR. The DIDIM uses floor projection as a stage for interactive
physical activity incorporating games, exercises and educational software. Content can
be customized according to the characteristics of the user or the institution where it is
installed, such as a school, gym, science museum, math camp, or senior center. The
system offers fitness training, real-time gaming via a multi-play feature, and a global
scoreboard, where one can connect and compete with other players around the world.
The DIDIM also provides brain training software comprised of memory, math, and
recognition-based activities that can help in developing or maintaining brain functions.
When the DIDIM is used for physical fitness, it provides a personal report of the user’s
workout history and results. The data measures the time one exercised, calories
burned, and other information to keep track of progress and results.
The DIDIM has a mobile control feature where users can connect their mobile
device to the DIDIM Kiosk to control the settings and programs, adjust difficulties,
receive information, and choose the games. The Kiosk can also be equipped with a
separate coin input device for commercial operation in department stores, hotels, game
centers, etc.
The device works by emitting laser pulses onto a floor and measuring the time it
takes for the light to return after reflecting off objects. The data is used to determine the
distance to various surfaces, creating a point cloud that represents the 3D structure of
the surveyed area. LiDAR is an active sensor, generating its own light source (laser) to
illuminate the scene. The LiDAR system emits rapid laser pulses, typically at rates
exceeding 100,000 times per second. The sensor measures the time it takes for each
pulse to travel to an object and return. The time, along with the speed of light, is used to
calculate the distance to the object. Each measurement creates a point in 3D space
with X, Y, and Z coordinates, forming a “point cloud” that represents the surveyed area.
3D LiDAR systems often use multiple lasers at different angles to capture a wider range
of data and create a more comprehensive 3D image.
The system is regularly updated for functionality and content via the internet. A
user can purchase additional content via the “shop” feature on the kiosk screen.
Other features include:
• A ticker signboard displaying with a rolling text message on the main screen that
an administrator can write and manage messages.
• A screensaver if the system hasn’t received any input for a certain time.
• “Cosmos” mode when an idling screen space emits a bang effect where
footsteps are detected.
• A Video player that plays a video contained in any connected USB drive.
• A “Foot Interface” function that allows the floor screen to be used for navigating
the user interface.
• A “multi-Kiosk setup” function that allows two machines to connect to each other,
working as one to allow more players to participate in a larger space.
ISSUE:
What is the tariff classification of the AR indoor exercise platform in question?
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LAW AND ANALYSIS:
Classification under the HTSUS is determined 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 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 may then be applied in their appropriate order.
The Harmonized Commodity Description and Coding System Explanatory Notes
(ENs) constitute the official interpretation of the Harmonized System at the international
level. While neither legally binding nor dispositive, the ENs provide a commentary on
the scope of each heading of the HTSUS and are generally indicative of the proper
interpretation of these headings. See T.D. 89-80, 54 Fed. Reg. 35127-28 (Aug. 23,
1989).
Although you request classification of the DIDIM under heading 9506, HTSUS,
as articles and equipment for general exercise, based on the description of the product,
it could potentially be classified in Section XVI of the HTSUS, which provides for certain
electronic devices. However, legal Note 1 (p) to Section XVI states that this Section
does not cover articles of Chapter 95, HTSUS. As such, the initial determination we
must make is whether the product is classified in Chapter 95. Heading 9506, HTSUS,
provides for:
9506 Articles and equipment for general physical exercise, gymnastics,
athletics, other sports (including table-tennis) or outdoor games, not
specified or included elsewhere in this chapter; swimming pools and
wading pools; parts and accessories thereof:
Other:
9506.91 Articles and equipment for general physical exercise,
gymnastics or athletics; parts and accessories
thereof
9506.99 Other:
Reading the legal texts, we see that the heading and subheading provide for,
inter alia, articles and equipment for general physical exercise, gymnastics or athletics.
Although there is no legal definition of these terms for tariff purposes, the Explanatory
Notes for heading 9506 provide a number of examples, such as trapeze bars and rings,
pommel horses, chest expanders, punching bags, skipping ropes, etc. The common
thread here is that all of the articles in the examples are physical devices which are
generally used for exercise, gymnastics, or athletics.
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The product at issue is described as an AR workout platform. Through the use of
integrated software and hardware, the kiosk guides the user through a variety of
workouts and physical challenges utilizing lasers and sensors. It incorporates
LiDAR sensing to track user motion and spatial interaction. DIDIM relies primarily on
digital processing and real-time feedback, functioning as an interactive motion capture
and visualization system rather than physical exercise hardware. The user interacts
with a projected virtual environment rather than traditional sports equipment.
From the information available, even brain-training exercises, which utilize brain
training software to facilitate memory, math, and recognition-based activities, are tied to
moving the body to answer the questions.
While the method of operation, i.e., through the use of lasers, projectors, and
sensors, is novel, the ultimate use of this device as an article or equipment for general
physical exercise, etc., fits squarely within the legal text of heading 9506, HTSUS.
In this respect, as heading 9506 provides for articles and equipment for general
physical exercise, and based on the on the commonly understood meaning of articles
used for general exercise, we find that the heading covers the instant product on the
basis of GRI 1. We note that you propose that the DIDIM should be classified in
heading 9506, subheading 9506.99, which provides for “Articles and equipment for
general physical exercise, gymnastics, athletics, other sports (including table-tennis) or
outdoor games, not specified or included elsewhere in this chapter; swimming pools and
wading pools; parts and accessories: Other: Other”. However, the DIDIM is described
under subheading 9506.91, which provides for articles and equipment for general
physical exercise, gymnastics, athletics, which, as explained above, covers this device.
Because the product at issue falls under the scope of the provision for articles
and equipment for general physical exercise, gymnastics, athletics under heading 9506,
it is excluded from Section XVI by application of Note 1 (p) to Section XVI. The DIDIM
is specifically classified in subheading 9506.91, HTSUS.
HOLDING:
By application of GRIs 1 and 6, the DIDIM is classified under heading 9506,
HTSUS, and specifically, subheading 9506.91.00, HTSUS, which provides for “Articles
and equipment for general physical exercise, gymnastics, athletics, other sports
(including table-tennis) or outdoor games, not specified or included elsewhere in this
chapter; swimming pools and wading pools; parts and accessories: Other: Articles and
equipment for general physical exercise, gymnastics or athletics; parts and accessories
thereof”. The general, column rate of duty applicable to goods is 4.6 percent ad
valorem.
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
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convenience and are subject to change. The text of the most recent HTSUS and the
accompanying duty rates are provided at http://www.usitc.gov/.
A copy of this ruling letter should be attached to the entry documents filed at the
time the goods are entered. If the documents have been filed without a copy, this ruling
should be brought to the attention of the CBP officer handling the transaction.
Sincerely,
Gregory Connor, Chief
Electronics, Machinery, Automotive,
and International Nomenclature Branch
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