Mr. Gordon C. Anderson
C.H. Robinson Worldwide, Inc.
14800 Charlson Road, Suite 400
Eden Praire, MN 55347-5048
RE: The tariff classification of various electric components for universal control units from China or Taiwan
Dear Mr. Anderson:
In your letter received June 19, 2009, you requested a tariff classification ruling. The samples which you submitted are being returned to you as requested.
The first item concerned is a radio frequency receiving device, model RM-433. The RM-433 contains a microprocessor that monitors all received signals so that RF noise and data from non-RTI transmitters is filtered out. This receiver unit allows RTI’s universal remote control units to communicate wirelessly with RTI control processor units via radio frequency transmitters. When a valid command is received by the RM-433 it passes the signal through its output driver which allows it to travel long distances over wire. The output driver is compatible with industry standard infrared repeating systems. The RM-433 is designed to operate with an RTI universal system controller and a central control system. It receives RF data, transmitted by a universal system controller, converts it to an electrical signal, and transfers it to the central control system using 3-conductor wire. Power is derived from the control system and no programming or setup is required.
The second item concerned is the XP-8 Advanced Control Processor. This unit is a high-end remote control processor for automating the operation of electronic systems in homes and office buildings. The XP-8 has been designed to interface seamlessly with all RTI remote controls and touch panels. The XP-8 is controlled by RTI handheld remotes and in wall controllers. Handheld remotes send radio frequency commands to the XP-8 using the “RM-433” antenna. The RTI in wall controllers send infrared commands to control the XP-8. The XP-8 is capable of controlling 3rd party equipment via RS-232, Infrared, Relays, as well as Ethernet control. The XP-8 stores system information including infrared and RS-232 commands using 32MB of non-volatile flash memory.
The third item concerned is the RP-6 Remote Control Processor. The RP-6 is an advanced programmable control system that is designed to automate the operations of audio and video systems such as home theaters. The RP-6 is controlled by RTI handheld remotes and in-wall controllers. Handheld remotes send radio frequency commands to the RP-6 using the “RM-433” antenna. RTI in-wall controllers send infrared commands to control the RP-6. The RP-6 itself is capable of controlling 3rd party equipment via RS-232, Infrared, as well as relay control. The RP-6 stores system information including infrared and RS-232 commands using 256Kb of non-volatile flash memory. All of the system’s control commands and sequences of commands are stored in non-volatile Flash memory within the RP-6.
The forth item concerned is the RP-1 Remote Control Processor. The RP-1 is designed to interface with RTI’s universal control units to automate the operation of audio/video and other electronic systems. This control processor features an integrated RF receiver, USB programming, RF signal reception, high output infrared port and is designed for single room installations. The RP-1 stores infrared commands using 256Kb of non-volatile memory. The RP-1 is programmed with standard Windows based PC using RTI programming software. The RP-1 controls any device capable of infrared control.
The fifth item concerned is the RCM-12 relay control module. This device consists of 12 electromechanical relays with normally open (NO) and normally closed (NC) contacts rated for up to 10 Amps (A) at 120 V. Contact operation is controlled by 12 Volt (V) coils. The relays can control any device which will react to a contact closure. Examples include motorized shades or drapes. The RCM-12 does not store any system commands or macros, nor does it transmit sound or data. It is controlled by any device capable of sending infrared commands, which included RTI handheld and in-wall products. Each RCM-1 has a switch that can be set to any of 10 different ID codes, allowing for use of multiple RCM-12 control modules in a single system. The relays are addressed by the remote control sending an infrared command to the RCM-12, directing it to open or close one of its twelve relays. Each relay is a single pole-double throw. This allows them to be wired for normally open, normally closed or toggle configuration.
You suggested that the classification of the RM-433 Radio Frequency Receiving Device should be under subheading 8517.69.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide are network): Other.” You also suggested that the classification of the XP-8, RP-6, RP-1 should be under subheading 8517.62.0050, HTSUS, which provides for “Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus.” However, the RM-433 (Radio Frequency Receiving Device), XP-8, RP-6, RP-1 (Remote Control Processors), and RCM-12 (Relay Control Module) are components used with RTI’s universal remote control and touch panel units found in complex and large electronic systems for home and office building applications. Within these electronic systems these components perform various functions, such as the controlling of contact closures and power sensors, automating the operation of audio/video and other electronic systems, providing addressable relays for controlling the likes of amplifiers to window coverings, and storing system information and commands using non-volatile flash memory. These components seem to be performing processing functions that are outside of the scope of heading 8517. As such, heading 8517 is inapplicable.
In your letter you also suggest classification of the RCM-12 Relay Control Module under subheading 8536.41.0020, HTSUS, for electromechanical relays. However, this device features a dozen relays, terminal strips and other connectors, combined within a panel or base used for the control and distribution of electricity, which is properly classified under heading 8537, HTSUS.
The applicable subheading for the RM-433 radio frequency receiving device, the XP-8 Advanced Control Processor, the RP-6 Remote Control Processor and the RP-1 Remote Control Processor will be 8543.70.9650, HTSUS, which provides for “Electrical machines and apparatus…: Other machines and apparatus: Other: Other: Other: Other.” The rate of duty will be 2.6%.
The applicable subheading for the RCM-12 Relay Control Module will be 8537.10.9070, HTSUS, which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Other.” The general rate of duty will be 2.7% ad valorem.
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 Steven M. Pollichino at (646) 733-3008, Thomas Campanelli at (646) 733-3016 or Linda M. Hackett (646) 733-3015.
Robert B. Swierupski
National Commodity Specialist Division