CLA-2-84:OT:RR:NC:N4:120
Cathy Spencer
Freight Expediters
6920 Engle Rd.
Middleburg Heights, OH 44130
RE: The tariff classification of Raspberry Pi from Great Britain
Dear Ms. Spencer:
In your letter dated April 4, 2017 you requested a tariff classification ruling on behalf of your client, International Products Sourcing Group. The sample you submitted for our review will be returned as requested.
The merchandise under consideration is referred to as the Raspberry Pi 2 Model B (P/N 70465426). You describe the Raspberry Pi as a credit card-sized, single board, fully functional personal computer (PC) which consists of a QUAD Core Broadcom processor, 1 GB memory, a 40 pin general purpose input/output (GPIO) extender, a micro SD slot, 4 USB ports, a HDMI port, audio and composite video ports, camera and display ports, and a micro USB port to receive power. The Raspberry Pi is capable of using multiple types of operating systems and has numerous applications available to download onto the device.
In use, the Raspberry Pi works as a miniature PC and allows the user to perform basic data processing functions and is commonly used in electronics based projects where computing functions are required but at a small size and cost. Additionally, the Raspberry Pi is used in a wide range of educational projects such as learning various program languages, the manipulation of hardware components with its GPIO slot, and networking functions. However, we must note that the Raspberry Pi is fully an open source device with modest computing power to perform tasks based solely on the needs of the user. In this regard, there are no hardware or software blocks preventing the end user from downloading and executing installed programs or off-the-shelf software applications, or gaining internet access, or performing tasks traditionally achieved by a typical laptop or desktop PC. The Raspberry Pi is a freely programmable PC and satisfies the following criteria set forth by Note 5(A) to Chapter 84, Harmonized Tariff Schedule of the United States (HTSUS):
Storing the processing program or programs and at least the data immediately necessary for the execution of the program;
Being freely programmed in accordance with the requirements of the user;
Performing arithmetical computations specified by the user; and
Executing, without human intervention, a processing program which requires them to modify their execution, by logical decision during the processing run.
The applicable subheading for the Raspberry Pi 2 Model B (P/N 70465426) will be 8471.50.0150, HTSUS, which provides for “Automatic data processing machines and units thereof… Processing units other than those of subheading 8471.41 or 8471.49, whether or not containing in the same housing one or two of the following types of unit: storage units, input units, output units: Other.” 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 https://hts.usitc.gov/current.
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 Karl Moosbrugger at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division