CLA-2-85:OT:RR:NC:N2:208
Ms. Caroline Yuan
Dogness Group LLC
4116 W Spring Creek Pkwy
Plano, TX 75024
RE: The tariff classification of Mini Treat Robot with camera from China
Dear Ms. Yuan:
In your letter received on December 14, 2018, you requested a tariff classification ruling. The submitted sample is being returned.
The merchandise under consideration is the Dogness Mini Treat Robot with camera, which consists of an HD camera, a microphone, a treat dispenser, and a laser pointer. This mini treat robot allows pet owners to remotely see their pets through a camera, hear their pets through a built-in microphone, interact with their pets by feeding them treats, and play with them through an interactive laser pointer all via an application on one’s smartphone or tablet. The camera captures video images and transmits them to an application outside the camera for remote viewing or recording. Moreover, based on the information provided the camera does not contain any inbuilt recording capability. The images can only be recorded on the user’s smartphone or tablet where the application is loaded. It is the opinion of this office, that the camera function performs the principal function of this composite machine.
The applicable subheading for the Dogness Mini Treat Robot with camera will be 8525.80.3010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Transmission apparatus for radio-broadcasting or television, whether or not incorporating reception apparatus or sound recording or reproducing apparatus; …: Television cameras, digital cameras and video camera recorders: Television cameras: Other: Color”. The rate of duty will be 0.5 percent 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 8525.80.3010, 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 8525.80.3010, 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 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 Lisa Cariello at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division