CLA-2-85:OT:RR:NC:N2:209
David Parker
Tiffany Sims CHB, Inc.
225 Corporate Center Dr. STE C
Stockbridge, GA 30252
RE: The tariff classification of a presentation system from China
Dear Mr. Parker:
In your letter dated October 18, 2018, you requested a tariff classification ruling on behalf of Barco, Inc.
This ruling request pertains to three versions of the “ClickShare Presentation System”
(product #’s CS-100, CSE-200, and CSE-800) as well as the “ClickShare Button” and “ClickShare Tray”.
The “ClickShare Presentation Systems” are wireless presentation and collaboration devices used in meeting rooms, boardrooms, and conference rooms. They allow anyone in the room to share content from their personal computer or smart device wirelessly to a presentation board. They consist of the “ClickShare Button” which connects to a personal computer via a USB port. The button transmits data from a personal computer to the “ClickShare Base Unit”. The base unit, which contains a decoder to interpret the received audio/video data, uses an HDMI cable to connect to a presentation board and controls the content of the meeting room display. The base unit wirelessly receives the transmitted data and the sound of the meeting room’s audio system from the “button(s)” and displays it on a presentation board via the HDMI cable. All three models allow users to share from a laptop, tablet, or smartphone directly to the presentation screen.
The “CS-100 ClickShare Presentation System” is for use in small meeting rooms. It includes a base unit and one button. The “ClickShare App” can also be used to share content from a mobile phone or tablet. It is a stand-alone model with one HDMI output, which allows 8 users to connect with one user sharing at a time. It includes security features such as encryption, login management, https, and the possibility to hide the SSID of the base unit’s wireless network.
The “CSE-200 ClickShare Presentation System” is for use in small to medium sized meeting rooms. It includes a base unit and two buttons and allows for up to two users to share simultaneously. The “ClickShare App” can also be used to share content from a mobile phone or tablet. It includes enhanced security and a wide range of connectivity options including AirPlay and Google Cast support for non-HDCP content as well as TouchBack support and central management. Security features can be set to one of three predefined levels, depending on the needs of the user. The device’s API makes integration much easier as it enables TouchBack in the meeting room.
The “CSE-800 ClickShare Presentation System” is for use in boardrooms, high-end meeting rooms, and conference rooms. It includes a base unit, four buttons, and one tray. It allows for up to eight users to share simultaneously. It features two HDMI inputs and outputs with a direct connection to legacy equipment and easy integration with conferencing systems. Connection to two 4K DCI displays can be driven by a single base unit. The two network connections allow separate and simultaneous connections to multiple networks (e.g. guest and corporate networks), and provide additional security and convenience for users.
The “ClickShare Button” is a USB device used to facilitate on screen sharing by setting up a wireless connection with the base unit. Available in USB-A and USB-C versions, it is used with CS-100, CSE-200, and CSE-800 products. Every button is paired with a base unit and multiple buttons can be paired to a single base unit.
The “ClickShare Tray” stores the buttons when they are not in use. It is designed to be placed on a meeting room table for easy accessibility. Each tray holds up to four buttons at one time. The tray is made of: 59.5 percent ABS Plastic (acrylonitrile butadiene styrene), an insert made of 23.5 percent stainless steel, 8.3 percent flannel bottom sheet attached to/under tray base, and a tray base made of 8.7 percent stainless steel.
You have suggested classification of the “ClickShareTray” in subheading 3923.90.0080, Harmonized Tariff System of the United States (HTSUS), which provides for articles for the conveyance or packing of goods, of plastics: Other: Other. However, Customs Headquarters has repeatedly ruled that the articles of heading 3923 are items, such as disposable packaging, that are used in the conveyance or packing of bulk goods and commercial goods in the stream of commerce, not personal effects or other items for possession of the consumer. The article under consideration is designed for storage of buttons that are the possession of the consumer. As such subheading 3923.90.0080 is not applicable.
The applicable subheading for the “CS-100 ClickShare Presentation System”, the “CSE-200 ClickShare Presentation System”, the “CSE-800 ClickShare Presentation System” and the “ClickShare Button” will be 8517.62.0090, HTSUS, which provides for “Telephone sets…; other apparatus for the transmission or reception of voice, images or other data...: Other apparatus for transmission or reception of voice, images or other data…: Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other.” The general rate of duty will be Free.
The applicable subheading for the “ClickShare Tray” will be 3926.90.9990, HTSUS, which provides for “Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other: Other.” The general rate of duty is 5.3 percent ad valorem.
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 the 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 for subheading 8517.62.0090, contact National Import Specialist Steven Pollichino at [email protected], and for subheading 3926.90.9990, contact National Import Specialist Kristopher Burton at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division