Mr. John M. Walters
Crimson Informatics, Inc.
4435 Waterfront Drive
Suite 306
Glen Allen, VA 23060

RE: The tariff classification of a navigational aid apparatus from various countries

Dear Mr. Walters:

In your letter dated January 24, 2012, you requested a tariff classification ruling.

The merchandise subject to this ruling request is a Micro-Electro-Mechanical device, model CTDOBD1, which contains a global positioning system (GPS), an accelerometer, a gyroscope, a magnetometer, and a modem. This device is installed in a vehicle and is used to track, record, and transmit data that it receives from the GPS, accelerometer, gyroscope, and magnetometer sensors. In addition, this merchandise transmits the data received by the sensors via a cellular modem to company servers. This device can be used to assist in fleet management, driving habits, or transportation research.

This merchandise is considered a composite machine and as such is classified in accordance with Legal Note 3 to Section XVI, Harmonized Tariff Schedule of the United States (HTSUS) and Legal Note 3 to Chapter 90, HTSUS. It is the opinion of this office that the principal function of this merchandise is being performed by the radio navigational aid (GPS) function and that the other sensors and the modem provide subsidiary functions.

The applicable subheading for this merchandise will be 8526.91.0040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Radar apparatus, radio navigational aid apparatus and radio remote control apparatus: Other: Radio navigational aid apparatus: 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

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 Lisa Cariello at (646) 733-3014.


Thomas J. Russo
National Commodity Specialist Division