CLA-2-85:OT:RR:NC:N4:410
Mr. Nolan Xie
Oriox Customs Broker Inc.
139 Mitchell Ave.
South San Francisco, CA 94080
RE: The tariff classification of a robotic vacuum cleaner from China
Dear Mr. Xie:
In your letter dated June 4, 2021, you requested a tariff classification ruling on behalf of Roborock Technology Co. Pictures and product specifications were submitted with your request.
The product is identified as the Roborock S7 Series Robotic Vacuum Cleaner. Based on the information and pictures that you have provided and the videos in the product websites, the Roborock S7 Series Robotic is a Wi-Fi connected vacuum robotic vacuum cleaner used to clean floors. The vacuum cleaner is for household use. It features a cleaning system allowing the vacuum cleaner to loosen, lift and suction dirt, dust and hair from hard floors and carpet. The vacuum cleaner consists of a round housing measuring approximately 350 mm in diameter and 96 mm in height with a self-contained electric motor and water tank inside. It has a mop cloth affixed to the mop cloth mount which will be vibrated by brushless motor. The peristaltic water pump sucks water from the water tank to the mop cloth to remove stains.
The vacuum is rated 100-240VAC and 28W with the dust cup capacity of 0.47 L. The vacuum cleaner is packaged with a rechargeable battery, a water tank, a mopping cloth, a VibraRise Mop Cloth Mount and a power cord for sale to individual consumers. Each unit is sold in a single package together with its corresponding accessories.
The applicable subheading for the Roborock S7 Series Robotic Vacuum Cleaner will be 8508.11.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Vacuum cleaners, parts thereof: With a self-contained electric motor: Of a power not exceeding 1,500 W and having a dust bag or other receptacle capacity not exceeding 20 l”. The rate of duty will be Free.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8508.11.0000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8508.11.0000, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading.
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 Michael Chen at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division