CLA-2-85:OT:RR:NC:N1:109
Mr. Gerry Tilton
Import/LAX
Kamino (KAT Import Brokers)
A Division of Kamino International Transport, Inc.
2580 Santa Fe Avenue
Redondo Beach, CA 90278
RE: The tariff classification of “The Sanctuary” from China
Dear Mr. Tilton:
In your letter dated May 20, 2008 you requested a tariff classification ruling, on behalf of your client Bluelounge Design of Pasadena, CA.
The merchandise subject to this ruling is called “The Sanctuary.” A sample of “The Sanctuary”, in its retail packaging, was submitted for classification purposes and is being returned as per your request. In your letter, you refer to “The Sanctuary” as a multiple dock charging device. However, unlike most docking stations, the sample reveals that this device does not contain a speaker to amplify the playback of music or to amplify other sounds.
“The Sanctuary” consists of a white plastic base with 12 built-in connections, an AC adapter, a reversible inner tray, and a user’s manual with a compatibility list. The 12 built-in connections enable the user to connect various types of consumer electrical devices, i.e., a cell phone, iPod, and other wireless mobile devices, to supply power to those devices and to recharge the batteries within those devices. The 12 built-in connections are of various sizes to fit into different types of cell phones, i.e., Nokia, Samsung, etc., and wireless mobile devices, i.e., an iPod, an iPhone, a Palm, etc.
The single pronged end of the AC adapter is plugged into “The Sanctuary” and the other (two pronged) end is plugged into the main (A/C wall outlet). The user then selects one of the built-in connections, compatible to the cell phone, iPod, etc., and plugs it into the device to provide power to it and to recharge its battery. “The Sanctuary” also has a port for a user to plug in their own USB charge cord to power-up and recharge various types of devices, such as Bluetooth headsets, portable games, etc. The user’s manual states that the reversible inner tray can be placed into the plastic base, where it would sit above the 12 built-in connections, so that an electronic device can rest on the inner tray while receiving power and being charged. The manual also states that you can rest items such as keys, a wallet, a watch, on the inner tray so that when an electronic device is being charged one’s pocketable accessories can all be in one place.
You suggested subheading 8504.50.4000, Harmonized Tariff Schedule of the United States (HTSUS), as the classification for “The Sanctuary.” Subheading 8504.50.4000 provides for “Other inductors: Power supplies for automatic data processing machines or units thereof of heading 8471; power supplies for goods of subheadings 8443.31 or 8443.32; power supplies for monitors of subheadings 8528.41 or 8528.51 or projectors of subheading 8528.61; for telecommunication apparatus.” However, “The Sanctuary” is not solely a power supply. It contains both a rectifying power supply (the AC adapter) and a battery charging device (within the white plastic base). The AC adapter converts the alternating current from the mains into direct current for further use within “The Sanctuary”, which is ultimately distributed to the circuitry within the white plastic base of “The Sanctuary”. The circuitry within the white plastic base of “The Sanctuary” dedicates the use of the white plastic base as a charging device. The portion of the white plastic base containing the circuitry also contains a light emitting diode (LED) to indicate that the AC adapter is plugged in and that “The Sanctuary” is ready for charging or is in the process of charging attached devices. The LED will also flicker, dim or go dark if too many devices are connected simultaneously. The flickering, dimming or darkness indicates that the unit has reduced or removed power from the connectors and may not charge any of the connected devices properly. As a functional unit, “The Sanctuary” is more appropriately provided for in subheading 8504.40.95 because the principal function is that of a charging device. As such, subheading 8504.50.4000 is inapplicable. The applicable subheading for “The Sanctuary” will be 8504.40.9550, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical transformers, static converters (for example, rectifiers)…:Static converters: Other: Rectifiers and rectifying apparatus: Other.” The rate of duty will be 1.5 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 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 Linda M. Hackett at 646-733-3015.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division