Krisanne Fischer
C/o Bernadette Placido-Mail Code 232
QVC, Inc.
1200 Wilson Drive
West Chester, PA 19380

RE: The tariff classification of the SMART Sketcher™ projector from China

Dear Ms. Fischer:

In your letter dated August 9, 2017, you requested a tariff classification ruling. A sample was provided.

The product at issue is identified as the SMART Sketcher™ drawing projector (item # T35184). The SMART Sketcher™ is a portable projector comprised of a plastic base unit topped by a projector head with an adjustable focusing lens, control buttons, and LED indicators. The product is designed to project still images onto a sheet of paper that a child can then sketch and trace. Images can be accessed electronically by means of a removable SD content card, and a user can cycle through the available images via the control buttons on the projector head. The SMART Sketcher™ projector is also capable of projecting images taken with a user’s smartphone. A user need simply download a SMART Sketcher™ app onto their phone and then connect the phone to the projector via Bluetooth.

Based on the information provided, the SMART Sketcher™ projector resembles a more advanced version of the drawing projectors described in New York Ruling Letters J82040 and K83575, dated April 10, 2003 and March 17, 2004 respectively. While the projectors in those rulings relied on slide disks to provide images to project, they were designed to project said images onto a sheet of paper so a child could trace them. The SMART Sketcher™ serves the same function as those projectors previously ruled upon, though it obtains its images electronically, via stored digital media or a Bluetooth connection, rather than using slides.

The applicable subheading for the SMART Sketcher™ projector will be 9008.50.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Image projectors, other than cinematographic; photographic (other than cinematographic) enlargers and reducers; parts and accessories thereof: Other image projectors. The rate of duty will be 4.6% 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 Evan Conceicao at [email protected].


Steven A. Mack
National Commodity Specialist Division