Mr. Milan H. Rafailovich
Aquagenesis International Incorporated
3631 Copley Avenue
San Diego, CA 92116

RE: The tariff classification of the RoboSnail from an unspecified country of origin

Dear Mr. Rafailovich:

In your letter dated January 24, 2012, you requested a tariff classification ruling. Product information and photographs of the RoboSnail were submitted for our review.

The article under consideration is identified as the RoboSnail. The RoboSnail is an automated aquarium glass/acrylic cleaner with a self-contained electric motor. The subject appliance is designed to clean the aquarium by keeping it clear of algae build-up on a daily basis without user intervention. The RoboSnail is comprised of three main components including a charging dock, an external battery powered drive unit and an inner cleaning member. The RoboSnail features an on/off switch, a replaceable battery, a scrubber that helps remove animals from the glass/acrylic, a replaceable scrubber pad and an automated cleaning mode. Once the RoboSnail has been programmed it will then self activate every 24 hours to do a cleaning cycle. After the appliance has performed its cleaning cycle it will return to its docking station where it will charge itself until its next scheduled cleaning time.

In your letter you suggest classification for the RoboSnail under heading 8543, Harmonized Tariff Schedule of the United States (HTSUS), which provides for wholly electrical items, with subsidiary mechanical attributes. The mechanical attributes of this device are not subsidiary, therefore, heading 8543, HTSUS, is not applicable. The appliance in question is classifiable under subheading 8509.80, HTSUS, which provides for electromechanical domestic appliances, with self-contained electric motor, other than vacuum cleaners of subheading 8508; parts thereof: other appliances.

The applicable subheading for the RoboSnail will be 8509.80.5095, HTSUS, which provides for electromechanical domestic appliances, with self-contained electric motor, other than vacuum cleaners of heading 8508; parts thereof: other appliances: other: other. The rate of duty will be 4.2 percent 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

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 Ann Taub at 646-733-3018.


Thomas J. Russo
National Commodity Specialist Division