CLA-2-85:OT:RR:NC:N1:109
Mr. Gerardo Blanco
Blanco Customs Brokerage, Incorporated
425A Pan American Drive
Suite #1
El Paso, TX 79907
RE: The tariff classification of Z-Wave Integrated Wireless Module from China
Dear Mr. Blanco:
In your letter dated September 5, 2012, you requested a tariff classification ruling on behalf of your client Protech Global Solutions, LP.
The merchandise subject to this ruling is a Z-Wave Integrated Wireless Module, ZM3102. The Z-Wave is a wireless communications protocol designed for home automation. The technology uses a low-power RF radio embedded or retrofitted into home electronics and systems, such as lighting, home access control, entertainment systems and household appliances.
The Z-Wave module is a general purpose module comprised of an integrated circuit and some support circuitry. The Z-Wave module enables wireless communication via a low power-low data rate mesh type network.
The Z-Wave chip is a printed circuit assembly that is manufactured using standard semiconductor techniques. The chip contains a microcontroller, a low power transmitter and a receiver. The external components include a crystal oscillator and passive components (resistors and capacitors). The purpose of the external components is to simplify the interface of the Zwave chip-to-external electronic hardware enabling the module to perform different functions by changing software. The principal function of the printed circuit assembly is Low power-Low Data rate communication at 908MHz, which will allow Stanley Black & Decker devices to communicate wirelessly with one another by receiving and transmitting data from and to Z-Wave chip.
You have suggested subheading 8534.00.0095, which provides for “Printed circuits”. However, the Z-Wave Integrated Wireless Module (ZM3102) is a wireless transmitter and receiver in the form of a printed circuit assembly. As such, it is a transceiver that functions within a network wirelessly and is classifiable within subheading 8517.62.
The applicable subheading for the Z-Wave Integrated Wireless Module, ZM3102, will be 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network): Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: 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 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 Hackett at (646) 733-3008.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division