Mr. Gio Scalzo
2001 Bryant Street
San Francisco, CA 94110
RE: The tariff classification of a Cold-Press Juice System from China
Dear Mr. Scalzo:
In your letter dated April 18, you requested a tariff classification ruling.
The merchandise under consideration is the countertop Cold-Press Juice System. The System is a domestic appliance with a self-contained motor. The System is designed to be placed on a flat surface and uses an external power cord to connect to a standard home electrical circuit. The System weighs 30 pounds and must be connected to a wireless internet (i.e. Wi-Fi) to pair it with the Juicero Cloud Interactive apps. The consumer must enroll in a subscription-based Pack delivery program. The Pack containing chopped up fruits or vegetables is individually inserted into the System that will extract the juice. The System will be registered to the specific consumer via an account that will track the user’s Pack inventory and subscription history. The System has a built-in camera that reads the respective Pack’s quick response (“QR”) code and communicates it with the Juicero apps. The Juicero apps maintains this alert structure so that the Juicero farm(s) can refill the consumer’s subscription and/or monitor use of demand for the respective Pack’s flavor. The System does not warm, brew, blend or provide any other processing to the contents of the Pack. You have suggested classification 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 area network): Other.”
Under GRI 1 and Section XVI Note 3, the item concerned is to be considered a composite machine. Despite the fact that this device incorporates additional parts and components such a transmission/reception module which allows for the transmission of various system statuses, the transmission/reception module does not change the principal function of the subject import as an electric juicing machine.
Based on the description and information provided, the principal function of the item concerned is not imparted by the transmission/reception module, this device would be beyond the scope of what was intended to be cover by heading 8517, HTSUS. Therefore, heading 8517, HTSUS, would not apply.
The applicable subheading for the Juicero Cold-Press Juice System, will be 8509.40.0030, HTSUS, which provides for electromechanical domestic appliances, with self-contained electric motor, other than vacuum cleaners of heading 8508, food grinders, processors and mixers; fruit or vegetable juice extractors, juice extractors. 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 https://hts.usitc.gov/current.
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 Hope Abada at firstname.lastname@example.org.
Deborah C. Marinucci
National Commodity Specialist Division