Mr. Peter A. Quinter
Gray Robinson, P.A.
333 SE 2nd Avenue Suite 3200
Miami, FL 33131
RE: The tariff classification of smartglasses lenses, nose-piece, and remote control from Israel
Dear Mr. Quinter:
In your letter dated February 14, 2018, on behalf of Everysight Ltd., you requested a tariff classification ruling. The submitted samples are being returned.
There are three items under consideration that are identified as the Everysight Raptor Visor, the Everysight Raptor RX Adaptor, and the Everysight Raptor Controller, which are all used with the Raptor smartglasses.
The Everysight Raptor Visors are tinted spectacle lenses that are exclusively designed to fit into the Raptor smartglasses. The Raptor’s visor provides clarity with an aerodynamic design that offers wind and impact protection. Moreover, the visor is easy to mount and maintain.
The Everysight Raptor RX adapter is a nosepiece used solely with the Raptor smartglasses frames that acts as a bridge used to hold prescription lenses and connects them to the raptor lens. Raptor’s frameless, lightweight RX adaptor replaces the nosepiece that comes with the raptor.
The Everysight Raptor Controller is a radio remote control device that controls the Raptor smartglasses from a distance through radio frequency. The controller uses Bluetooth Low Energy technology and comes with a standard CR2032 coin cell battery.
In your requests, you suggest that all three subject items are classified in subheading 8517.70.000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Other apparatus for transmission and 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 than transmission or reception apparatus of heading 8443, 8525, 8527 or 8528; parts thereof: Parts." However, these items are more specifically provided for elsewhere in the tariff.
The applicable subheading for the Eversight Raptor Visors will be 9001.50.0000, HTSUS, which provides for spectacle lenses of other materials. The rate of duty will be 2 percent ad valorem.
The applicable subheading for the Everysight Raptor RX adaptor will be 9003.90.0000, HTSUS, which provides for parts of frames and mountings for spectacles, goggles or the like. The rate of duty will be 2.5 percent ad valorem.
The applicable subheading for the Everysight Raptor Controller will be 8526.92.5000, HTSUS, which provides for Radar apparatus, radio navigational aid apparatus and radio remote control apparatus: Other: Radio remote control apparatus: Other. The rate of duty will be 2.4 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 Lisa Cariello at email@example.com.
Steven A. Mack
National Commodity Specialist Division