CLA-2-84:OT:RR:NC:N1:120

Ms. Cindy Hazlett
Belkin International
12045 East Waterfront Drive
Playa Vista, CA 90094

RE: The tariff classification of the Belkin Tablet Stage from China

Dear Ms. Hazlett:

In your letter dated May 7, 2013, you requested a tariff classification ruling.

The merchandise under consideration is the Belkin Tablet Stage that is identifiable as an adjustable stand intended to hold an electronic tablet (not imported) measuring between 7 and 11 inches. This merchandise, which is imported as an unassembled unit, comprises a metal pole, a base, a tablet cradle, a light clip, an LED (light-emitting diode) light, five screws, and three AAA batteries.

The Tablet Stage has an adjustable metal pole, referred to as “the post,” secured to the base of its stand in order to adjust the height of the tablet. It also has an adjustable platform cradle that is inserted into the top of the pole’s arm to hold the tablet and rotate it into a horizontal or vertical position. The cradle features a cutout for the tablet’s camera lens. When held in a horizontal position, the tablet can record activity and capture images via its camera mode; and when rotated in a vertical position, the tablet can be used as a display screen. The LED light, which is battery-operated, has a gooseneck body with an adjustable clip to attach to the pole of the Tablet Stage in order to provide low or high light to objects placed on its base.

The Belkin Tablet Stage is specifically designed for and principally used with automatic data processing (ADP) units, i.e., tablets, to enhance their function and operation. Noting the Explanatory Notes for heading 8473 of the Harmonized Tariff Schedule of the United States (HTSUS), the Tablet Stage would meet the definition of an accessory for an ADP system.

The applicable subheading for the Belkin Tablet Stage will be 8473.30.5100, HTSUS, which provides for Parts and accessories (other than covers, carrying cases and the like) suitable for use solely or principally with machines of headings 8469-8472: Parts and accessories of the machines of heading 8471: Not incorporating a cathode ray tube: 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 Denise Faingar at (646) 733-3010.

Sincerely,

Thomas J. Russo
Director
National Commodity Specialist Division