CLA-2-84:OT:RR:NC:N2:220
Poonam Parekh
MP Custom Brokers, Inc.
556 Sequoia Trail
Roselle, Illinois 60172
RE: The tariff classification of docking stations from China
Dear Mr. Parekh:
In your letter dated November 1, 2019 you requested a tariff classification ruling on behalf of your client, VisionTek Products, LLC.
The first item under consideration is identified as the VT4000 Dual 4K Universal Docking Station (VT4000), Item #901005, which is described as a plastic enclosure having two HDMI ports, two DisplayPorts, audio lines in/out, one RJ45 Ethernet Port, six USB 3.0 Ports, and a single USB-C Port. The principal function of the VT4000 is to provide users with the ability to connect an automatic data processing (ADP) machine to two display monitors, and up to eleven accessories and peripherals through a single USB-C input connection. The peripherals, which are connected to the USB 3.0 Ports, may include a keyboard, a mouse, an external storage unit, etc. and allow the connected ADP machine to interface and control the attached units while the connected display monitor(s) provide users with the display output of the connected ADP machine.
The second item under consideration is identified as the VT4500 Dual 4K Monitor Universal Docking Station with Power Delivery (VT4500), Item #901250, which is described as a plastic enclosure having two HDMI ports, two DisplayPorts, audio lines in/out, one RJ45 Ethernet Port, four USB 3.0 Ports, and three USB-C Ports. The principal function of the VT4500 is to provide users with the ability to connect an ADP machine to two display monitors, and up to eleven accessories and peripherals through a single USB-C input connection. The peripherals, which are connected to the USB-C and 3.0 Ports, may include a keyboard, a mouse, an external storage unit, etc. and allow the connected ADP machine to interface and control the attached units while the connected display monitor(s) provide users with the display output of the connected ADP machine.
The third item under consideration is identified as the VT1000 Dual Monitor Universal Docking Station (VT1000), Item #901147, which is described as a plastic enclosure having one HDMI port, one DisplayPort, one VGA Port, audio in/out, one RJ45 Ethernet Port, three USB 3.0 Ports, and a single standard USB input connection. The principal function of the VT1000 is to provide users with the ability to connect an ADP machine to two display monitors, and up to four accessories and peripherals through a single USB input connection. The peripherals, which are connected to the USB 3.0 Ports, may include a keyboard, a mouse, an external storage unit, etc. and allow the connected ADP machine to interface and control the attached units while the connected display monitor(s) provide users with the display output of the connected ADP machine.
The fourth item under consideration is identified as the VT100 Dual 4K Universal Portable Docking Station (VT100), Item #901200, which is described as a plastic enclosure having one HDMI port, one VGA Port, one RJ45 Ethernet Port, one USB 3.0 Port, one SD memory card slot, one SD-Micro memory card slot, and a single USB 3.0 input connection. The principal function of the VT100 is to provide users with the ability to connect an ADP machine to two display monitors, and an additional accessory/peripheral through a single USB input connection. The peripherals, which are connected to the USB 3.0 Port, may include a keyboard, or a mouse, or an external storage unit, etc. and allow the connected ADP machine to interface and control the attached unit while the connected display monitor(s) provide users with the display output of the connected ADP machine.
In your request, you suggest the four docking stations are correctly classified under subheading 8473.30.1180, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Parts and accessories … suitable for use solely or principally with machines of headings 8469 to 8472: Parts and accessories of the machines of heading 8471: Not incorporating a cathode ray tube: Printed circuit assemblies." We disagree.
The General Rules of Interpretation (GRIs) to the HTSUS govern the classification of goods in the tariff schedule. GRI-1 states, in pertinent part, that "for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes . . . ." And although not dispositive, the Explanatory Notes (ENs) to the Harmonized Commodity Description and Coding System represent the official interpretation of the tariff at the international level and facilitate classification under the HTSUS by offering guidance in understanding the scope of the headings and the GRIs.
Stated previously, each of the subject docking stations connect directly to an ADP machine for the purpose of providing an interconnection between the ADP machine and peripherals. The ENs describe such units as those that “effect interconnections of the central processing unit to input or output units (e.g., USB hubs)”. As this control function is specifically provided for under heading 8471, the subject docking stations are classified accordingly.
The applicable subheading for the VT4000 Dual 4K Universal Docking Station, Item #901005, the VT4500 Dual 4K Monitor Universal Docking Station with Power Delivery, Item #901250, the VT1000 Dual Monitor Universal Docking Station, Item #901147, and the VT100 Dual 4K Universal Portable Docking Station, Item #901200 will be 8471.80.1000, HTSUS, which provides for “Automatic data processing machines and units thereof…: Other units of automatic data processing machines: Control or adapter units.” The rate of duty will be Free.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8471.80.1000, HTSUS, unless specifically excluded, are subject to an additional 25 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 8471.80.1000, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at:
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions https://www.cbp.gov/trade/remedies/301-certain-products-china
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 Karl Moosbrugger at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division