CLA-2-85:OT:RR:NC:N2:212

Robert Fils
Aquatic AV
282 Kinney Drive
San Jose, CA 95112

RE: The tariff classification of a sound transducer from China

Dear Mr. Fils:

In your letter dated June 3, 2021, you requested a tariff classification ruling.

The merchandise under consideration is described as a waterproof audio transducer. The subject unit is cylindrical in shape and designed to be attached to any flat surface. When connected to a speaker via the incorporated speaker wires, the transducer converts this sound energy to mechanical energy by vibrating the surface onto which it is attached. This vibration effectively turns the surface into a speaker, creating the desired sounds or music. You state that the subject device is primarily used in environments where a traditional speaker could be compromised by water, fog, or UV light.

The applicable subheading for the waterproof audio transducer will be 8543.70.4500, 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: Electric synchros and transducers; flight data recorders; defrosters and demisters with electric resistors for aircraft: Other.” The general rate of duty will be 2.6% ad valorem.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8543.70.4500, 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 subheading 8543.70.4500, 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, including information on exclusions and their effective dates, 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 Luke LePage at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division