Maher M. Shomali
Thomsen and Burke LLP
Two Hamill Road, Suite 415
Baltimore, MD 21210
RE: The tariff classification of energy meters from China
Dear Mr. Shomali:
In your letter dated January 4, 2018, on behalf of Currant Inc., you requested a tariff classification ruling.
Your submission concerns two models of Currant Energy Meters, described as a standalone “plug-in” device and an “in-wall” device. The primary purpose of the Currant Energy Meters is to measure the amount of electricity consumed by appliances that are plugged into each device.
The standalone “plug-in” energy meter allows a user to insert the device into an existing grounded household electrical outlet. This model of energy meter contains two receptacles for receiving the 2- or 3- prong plugs of independent electrical appliances and measures approximately 2.5" x 3.5" x 1.5". The “in-wall” energy meter is intended for installation into a homeowner’s wall as a replacement for a traditional electrical wall outlet. The “in-wall” model resembles a traditional household outlet and contains two receptacles for receiving 2 or 3-prong plugs.
Both Currant Energy Meter models have the ability to accurately record and report the electrical consumption of any appliance plugged into the device. Energy consumption data are transmitted wirelessly via Wi-Fi or Bluetooth, and can be accessed using a smartphone by means of a specially downloaded app. The smartphone app enables a user to monitor an appliance’s real-time and historical electrical consumption, and will estimate the cost of the electricity consumed based on the user’s location and electricity provider.
The Currant Energy Meters at issue serve a function similar to that of the energy monitors described in New York Ruling Letter N225777, dated July 24, 2012.
The applicable subheading for the Currant Energy Meters will be 9028.30.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Gas, liquid or electricity supply or production meters, including calibrating meters thereof; parts and accessories thereof: Electricity meters. The rate of duty will be 8 cents each plus 0.7% 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 Evan Conceicao at [email protected].
Steven A. Mack
National Commodity Specialist Division