Elisabeth Forrest
Global Trade Compliance Analyst
345 Encinal Street
Santa Cruz, CA 95060

RE: The tariff classification of APT-31 EHS cable from Mexico

Dear Ms. Forrest:

In your letter dated June 26, 2013, you requested a tariff classification ruling.

The merchandise in question is known as the APT-31 EHS cable. This cable consists of a cable with connectors at both ends. One end has a modular connector and the other end has a connector made to fit a specific telephone model. A printed circuit board in plastic housing is attached to the middle of the cable. The printed circuit board contains capacitors, diodes, resistors, integrated circuits and a port/jack for accessory devices. The APT-31 EHS cable uses the printed circuit board to convert the signal from the headset base to a brand specific telephone signal which the telephone can understand.

The APT-31 EHS cable plugs into a telephone on one end and a Plantronics headset base on the other. The cable sends signals between the telephone and the headset base; it answers calls, sends voice signals, adjusts volume, and mutes the voice signal. The printed circuit board in the middle of the cable processes and routes the signal through the cable in order to control the telephone’s functions. There is no manual switching apparatus and no buttons on the cable; the routing and controlling functionality is controlled by the printed circuit board. The APT-31 EHS cable is a composite machine that functions as both an electrical cable and a converter. It has been determined that there is no apparatus performing the principal function of this composite machine. Where it is not possible to determine the principal function, and where, as provided in Note 3 to Section XVI of the Harmonized Tariff Schedule of the United States (HTSUS), the context does not otherwise require, it is necessary to apply General Interpretative Rule 3(c). In such cases, classification shall be in the provision which occurs last in numerical order among those which equally merit consideration. The headings which equally merit consideration are heading 8517, HTSUS (the printed circuit board device), and heading 8544, HTSUS (the cable fitted with connectors). Based on the above, classification of this composite machine will be under heading 8544, HTSUS. The applicable subheading for the APT-31 EHS cable will be 8544.42.1000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Insulated wire, cable…: Other electric conductors, for a voltage not exceeding 1,000 V: Fitted with connectors: Fitted with modular telephone connectors." The general 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 Josephine Heaning at (646) 733-3015.


Thomas J. Russo
National Commodity Specialist Division