CLA-2-90:OT:RR:NC:N1:405

Ms. Katherine G. Lyons
United States Foundation for Inspiration
and Recognition of Science and Technology
200 Bedford Street, Unit 108
Manchester, NH 03101

RE: The tariff classification of educational robots from various countries

Dear Ms. Lyons:

In your letter dated October 22, 2015 you requested a tariff classification ruling.

The products under consideration are un-programmed educational robots being imported exclusively for foreign student teams participating in the United States Foundation for Inspiration and Recognition of Science and Technology (U.S. FIRST®) robotic competitions.

Upon registration, each overseas team is sent a U.S. FIRST® issued “kit of parts” which includes those parts necessary to assemble a single educational robot. This kit contains, among other things, a small 12-volt battery, drive wheels, small DC motors, a programmable controller made by National Instruments for Student Robotics and a game manual. Utilizing these parts, the student teams have the ability to build their own uniquely designed creation. You have indicated that the students also have the option of including additional pieces (within competition guidelines) to give further distinction to their robot. Programming of the robot will take place after it has reached the U.S. competition site.

Each year, US FIRST® assigns a different game/challenge. The teams, comprised of students (ages 14-18) and their mentors have six weeks to design and build their robots using a certain set of criteria. While trying to overcome the challenge at hand, the students learn problem solving, programming, manufacturing, quality control, assembly practice, logistics, marketing, project management, and time management. You indicate that the subject robots are for educational purposes only and used exclusively for student competitions. After the competition, each student team has the option of taking their robot home.

The applicable subheading for the educational robots will be 9023.00.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Instruments, apparatus and models, designed for demonstrational purposes (for example, in education or exhibitions), unsuitable for other uses, and parts and accessories thereof. The 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 on World Wide Web at http://www.usitc.gov/tata/hts/.

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 April Cutuli at [email protected].

Sincerely,

Gwenn Klein Kirschner
Director
National Commodity Specialist Division