6920 Engle Rd. Suite II
Middleburg Heights, OH 44130
RE: The tariff classification of the Picade HAT Kit from Great Britain
Dear Ms. Spencer:
In your letter dated August 21, 2017 you requested a tariff classification ruling on behalf of your client, International Products Sourcing Group.
The merchandise under consideration is referred to as the Picade HAT Kit and is said to be an accessory component used exclusively with the Raspberry Pi. Accessories for the Raspberry Pi are commonly referred to as a “HAT” or a “pHAT.” These acronyms represent the method of affixing the devices to the Raspberry Pi and simply stand for the term “Hardware Attached on Top.” The term “pHAT” merely identifies a smaller version of the HAT. Generally, HATs and pHATs are printed circuit board assemblies that perform a variety of specific functions and incorporate a mounted EEPROM which identifies the device to the Raspberry Pi.
The subject Picade HAT Kit consists of a small printed circuit board assembly (PCBA), 11 arcade style momentary contact pushbuttons, a joystick, and a speaker. The PCBA is described as having two multipoint terminal strips on the top, control and audio amplifier circuits, a micro-USB connector for power, and a 40-pin general purpose input/output (GPIO) connector on the bottom. The terminal strips are used to connect an arcade style joystick and button switches by inserting the insulated wire into the strip and fastening each with a set screw. The Picade HAT is attached to the Raspberry Pi via the GPIO connector and once installed with the supplied switches, the Raspberry Pi emulates an arcade style video game console.
The instant kit consists of two or more different articles that are, prima facie, classifiable in different headings. The Picade HAT Kit also consists of articles put up together to carry out a specific activity (i.e., electrical interconnection). Finally, the articles are put up in a manner suitable for sale directly to users without repacking. Therefore, the kit in question is described within the meaning of "goods put up in sets for retail sale."
General Rule of Interpretation ("GRI") 3(b) states in part that goods put up in sets for retail sale, which cannot be classified by reference to GRI 3(a), are to be classified as if they consisted of the component which gives them their essential character. It is the opinion of this office that the PCBA and momentary contact pushbutton switches impart the essential character of the Picade HAT Kit.
The applicable subheading for the Picade HAT Kit will be 8537.10.9170, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Other.” The rate of duty will be 2.7 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 Karl Moosbrugger at firstname.lastname@example.org.
Steven A. Mack
National Commodity Specialist Division