Allen J. Holt
701 Brooks Ave S.
Thief River Falls, MN 56701
RE: The tariff classification of the GrovePi Zero Base Kit from China
Dear Mr. Holt:
In your letter dated January 4, 2018 you requested a tariff classification ruling.
The merchandise under consideration is referred to as the GrovePi Zero Base Kit that is said to be used exclusively with the Raspberry Pi personal computer (PC). The GrovePi Zero Base Kit consists of a small printed circuit board assembly (PCBA) controller and numerous electrical apparatus and components that are packaged in a retail box ready for the consumer to perform various electrical projects. The PCBA, which serves as a controller board with eight multi-pin connectors, is attached to the general purpose input/output (GPIO) connector of the Raspberry Pi. You state that the Raspberry Pi is not included in the kit.
The subject kit includes individually packaged sensors, (temperature, humidity, light, range, angle, and sound), and various electrical components such as LEDs, a relay, a pushbutton, a liquid crystal display, a protective acrylic case, and numerous cables to connect these devices. Users would connect the PCBA to their Raspberry Pi and by attaching any of the included sensors they have the ability to program and control them through the open source software residing on the connected PC.
The GrovePi Zero Base Kit consists of two or more different articles that are, prima facie, classifiable in different headings. The GrovePi Zero Base 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 imparts the essential character of the GrovePi Zero Base Kit.
In your request, you suggest that the GrovePi Zero Base Kit is correctly classified as an automatic data processing machine under 8471.50.0150, Harmonized Tariff Schedule of the United States (HTSUS). As the function of the control board is to connect electrical apparatus to the Raspberry Pi PC and allow for the control of those apparatus, the subject kit would not meet the requirements of Chapter 84 Note 5, HTSUS, and heading 8471 is not appropriate. The applicable subheading for the GrovePi Zero Base Kit will be 8537.10.9170, 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