UPS Supply Chain Solutions
500 Rutherford Ave.
Charlestown, MA 02129
RE: The tariff classification of two models of radio frequency receivers (Part #s R7 and R8) and a radio frequency transmitter (Part # PT4) from China.
Dear Ms. Newton:
In your letter dated July 17, 2007, you requested a tariff classification ruling on behalf of your client, DogWatch Hidden Fence Systems.
The articles concerned are components of the DogWatch hidden fence system. The entire DogWatch hidden fence system is used to contain/restrict a dog to a particular area, without the use of a physical fence. Part numbers R7 and R8 are printed circuit board assemblies which make up the radio frequency receiver portion of this system. These R.F. receiver assemblies will be incorporated into a plastic housing which is mounted on a dog collar. Part number PT4 is a radio frequency transmitter. This R.F. transmitter connects to a boundary wire which is buried along the perimeter of the containment area.
In use, a boundary wire is buried along the perimeter of the containment area. That boundary wire connects to the transmitter (Part # PT4) and acts as an antenna. The transmitter transmits radio frequency signals through the boundary wire to the dog collar receivers (Part #s R7 and R8). Based on those signals the collars will issue an audible warning to the dog as it approaches the boundary line. As the dog is trained, it will learn to recognize that audible signal and its meaning (to stop at the pre-determined boundary line). If the dog does not respond to the audible signal, the collar will use a mild electric shock as a stronger deterrent to keep the dog within the boundaries.
The applicable subheading for the receiver assemblies, (Part #s R7 and R8) will be 8531.90.3000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric sound or visual signaling apparatus...: Parts: Printed circuit assemblies: Other”. The rate of duty will be 1.3%.
The applicable subheading for the radio frequency transmitter (Part # PT4)
will be 8517.69.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “…other apparatus for the transmission or reception of voice, images or other data…: Other apparatus for transmission or reception of voice, images or other data…: Other”. The rate of duty will be Free.
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 http://www.usitc.gov/tata/hts/.
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 Steve Pollichino at 646-733-3008.
Robert B. Swierupski