CLA-2-85:OT:RR:NC:N2:209
Mark C. Hamilton
C.H. Robinson
4659 World Parkway Circle
St. Louis, MO 63134
RE: The tariff classification of home alarms from China
Dear Mr. Hamilton:
In your letter dated November 6, 2018, you requested a tariff classification ruling on behalf of your client, Security Equipment Corporation.
The first item concerned is a 5-component home alarm system (item WP-100). This system consists of one tri-color LCD display panel, one motion sensor with a directional mounting bracket, two door/window sensors, and one key fob remote control. The motion sensor and door/window sensors are battery powered. The smart panel comes with an AC adaptor. The display panel communicates with the sensors via IR. When the sensors are activated an alarm siren will sound.
The second item concerned is a door/window alarm (item HS-DWA). This is a two part battery powered alarm. It consists of a sensor unit and an alarm unit. The sensor unit would be mounted next to the alarm unit, one on a door/window the other on an adjacent wall. The two units have an electro-magnetic connection. When the door/window moves, the connection between the two units is disrupted. Once the connection is broken an alarm will sound at up to 120 DB. The item has three modes: off, chime, and alarm.
The third item concerned is a home, shed, or garage alarm (item HS-EDA). This is a two part alarm. It consists of a key panel and a sensor. The sensor unit would be mounted next to the key panel unit, one on a door the other on an adjacent wall. The two units have an electro-magnetic connection. When the door moves the connection between the two units is disrupted. Once the connection is broken an alarm will sound at up to 120 DB. The keypad serves to allow the user to arm and disarm the alarm.
The applicable subheading for the 5-component home alarm system (item WP-100), the door/window alarm (item HS-DWA), and the home, shed, or garage alarm (item HS-EDA) will be 8531.10.0035, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric sound or visual signaling apparatus (for example, bells, sirens, indicator panels, burglar or fire alarms), other than those of heading 8512 or 8530; parts thereof: Burglar or fire alarms and similar apparatus: Other: Burglar alarms.” The rate of duty will be 1.3% ad valorem.
Effective July 6, 2018, the Office of the United States Trade Representative (USTR) imposed an additional tariff on certain products of China classified in the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), HTSUS. The USTR imposed additional tariffs, effective August 23, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(d), HTSUS. Subsequently, the USTR imposed further tariffs, effective September 24, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(f) and U.S. Note 20(g), HTSUS. For additional information, please see the relevant Federal Register notices dated June 20, 2018 (83 F.R. 28710), August 16, 2018 (83 F.R. 40823), and September 21, 2018 (83 F.R. 47974). Products of China that are provided for in subheading 9903.88.01, 9903.88.02, 9903.88.03, or 9903.88.04 and classified in one of the subheadings enumerated in U.S. Note 20(b), U.S. Note 20(d), U.S. Note 20(f) or U.S. Note 20(g) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees and charges that apply to such products, as well as to those imposed by the aforementioned Chapter 99 subheadings.
Products of China classified under subheading 8531.10.00, HTSUS, unless specifically excluded, are subject to the additional 10 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 8531.10.0035, HTSUS, listed above.
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 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, contact National Import Specialist Steven Pollichino at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division