Mr. Anthony Johnson
Air and Ground World Transport
3014 E. Via Mondo
Rancho Dominguez, CA 90221

RE: The tariff classification of mobile tracking devices from China

Dear Mr. Johnson:

In your letter dated November 19, 2014, on behalf of Novatel Wireless, you requested a tariff classification ruling.

The merchandise under consideration is the mobile tracking devices, models MT 3060 and MT 4000. Both mobile tracking devices contain an internal GPS, a cellular antenna, and an internal SIM card holder. These devices, which are installed in a vehicle, are used to monitor status, performance, and location of the vehicle. In addition to navigating where a vehicle is located, these devices communicate data back to a server by using cellular modems to report the information gathered. These devices can be used to assist in fleet management.

You have stated that these devices, each equipped with a cellular module, are similar to the “module” within NY ruling decision N185515, dated October 20, 2011. The embedded module in the aforementioned ruling decision was classified in subheading 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Modems, of a kind used with data processing machines of heading 8471. However, since each subject tracking device functions as a GPS device with transmission capability, it is the opinion of this office that the subject merchandise is properly classified as radio navigational aid apparatus, thereby excluding classification in subheading 8517.62.0050, HTSUS.

The applicable subheading for these mobile tracking devices will be 8526.91.0040, 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


Gwenn Klein Kirschner
National Commodity Specialist Division