CLA-2-90:OT:RR:NC:N1:105
Beth A. Anderson
Principle Consultant
B.A. Quality Systems Consulting, LLC
46492 381St Ave.
Saint Peter, Minnesota 56082
RE: The tariff classification of Water Detection Devices and Humidity Sensor from China
Dear Ms. Anderson:
In your letter dated November 24, 2020, on behalf of NextGen RF Design, you requested a tariff classification ruling.
The first item under consideration is the WaterBug 200 water detection device. The device is designed to detect water (other than distilled water) and notify the user via a separate alarm system. The WaterBug 200 does not have a self-contained warning alarm. The device is designed so that the control console mounts on a wall or other flat vertical surface and the remote probes are placed in locations where water leakage is most probable. Up to six remote probes may be connected to one control console. In operation, when water forms a bridge between two of the metallic contacts, the device sends a notification to the alarm system (sold separately) to signal an alarm condition.
The second item under consideration is the WaterBug 350 water detection device. The device is designed to detect water (other than distilled water) and provide an alert notification to a user. In addition to sending an alert signal to an alarm system, the WaterBug 350 also has a built-in buzzer alarm. Up to six remote probes may be connected to one control console. In operation, when water forms a bridge between two of the metallic contacts, the device signals an alarm condition. The WaterBug 350 is imported with the WB-350 console, one surface probe and installation instructions. The WaterBug 350 is powered by a 9 volt battery.
The third item under consideration is the WaterBug 800 water detection device. The device is designed to detect water (other than distilled water) and provide an alert notification to a user. In addition to sending an alert signal to an alarm system, the WaterBug 800 also has a built-in buzzer and LED alarm. In operation, when water forms a bridge between two of the metallic contacts, the device signals an alarm condition. The WaterBug 800 is imported with the WB-800 console, four supervised surface sensors, a mounting box, mounting screws and installation instructions. The WaterBug 800 is hardwired to any wireless alarm system and can connect up to 8 supervised sensors and 16 unsupervised sensors.
The fourth item under consideration is the HA-III+ Humidity Sensor. The humidity sensor provides an analog voltage/current level through a wired connection, which is translated into a relative humidity reading (within a tolerance) by the EnviroAlert consoles. The device is designed to monitor the relative humidity levels in rooms however not in extreme conditions such as freezers. The sensor can be used with up to one thousand feet of 22 AWG twisted pair wire cable, which is sold separately. The sensor is imported with the humidity sensor, mounting screws, and an instruction manual. The device measures 3 inches, by 2 inches, by 1.75 inches and weighs 5 ounces.
The applicable subheading for the WaterBug 200 will be 8543.70.9960, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other: Other: Other.” The general rate of duty will be 2.6% ad valorem.
The applicable subheading for the WaterBug 350 will be 8531.80.9041, 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: Other apparatus: Other: Other sound signaling apparatus.” The general rate of duty will be free.
The applicable subheading for the WaterBug 800 will be 8531.80.9051, 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: Other apparatus: Other: Other.” The general rate of duty will be free.
The applicable subheading for the HA-III+ Humidity Sensor will be 9025.80.1000, HTSUS, which provides for “Hydrometers and similar floating instruments, thermometers, pyrometers, barometers, hygrometers and psychrometers, recording or not, and any combination of these instruments; parts and accessories thereof: Other instruments: Electrical.” The general rate of duty will be 1.7% ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 9025.80.1000 and 8543.70.9960, 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., 9903.88.02, in addition to subheadings 9025.80.1000 and 8543.70.9960, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 8531.80.9041 and 8531.80.9051, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheadings 8531.80.9041 and 8531.80.9051, 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 Jason M. Christie at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division