Carl W. Mertz
TP-Link USA Corp
145 South State College Blvd Suite 400
Brea, CA 92821
RE: The tariff classification of antennas and an antenna cable from China
Dear Mr. Mertz:
In your letter dated October 30, 2018, you requested a tariff classification ruling.
The items concerned are referred to as antennas (model #’s TL-ANT2408CL, TL-ANT2412D, and TL-ANT2409A) and an antenna extension cable (model # TL-ANT24EC3S).
The first item concerned (model # TL-ANT2408CL) is a 2.4GHz 8dBi indoor Omni-Directional (transmits in a 360 degree) antenna containing an RP-SMA female connection point. It is designed to be a high power replacement to a standard antenna shipped with a 2.4GHz wireless router, although it can be used with any 2.4GHz product that has an RP-SMA male antenna connector. This device has a horizontal beam width of 360 degrees and a vertical beam width of 15 degrees. Its polarization is linear and vertical, and its impedance is 50 Ohms.
The second item concerned (model # TL-ANT2412D) is a 2.4GHz 15dBi outdoor Omni-Directional antenna containing an N-type female connector and a weatherproof design making it suitable for all weather conditions. It weighs 0.6kg has an impedance of 50 Ohms, its beam width is 360 degrees horizontal and 9 degrees vertical, and its polarization is linear and vertical. The operating temperatures of this device range from -40 degrees F to 149 degrees F. Operation humidity is 10% to 90% non-condensing. The product conforms to CE, FCC and RoHS rules.
The third item concerned (model # TL-ANT2409A) is a 2.4GHz 9dBI directional antenna designed for point to point communication or to provide indoor or outdoor coverage. It has a built in 100cm (39.4in) CFD-200 low loss cable with a RP-SMA female connector. Its beam width is 60 degrees horizontal and 76 degrees vertical. The device can be mounted via pole or wall and has an approximate range of 1.77km/1km/140m when using 1/11/54 Mbps, respectively.
The fourth item concerned (model # TL-ANT24EC3S) is a 3 meter co-axial extension cable. One end incorporates a RP-SMA male connector to connect to the existing antenna cable. The other end incorporates an RP-SMA female connector to connect to a router or AP. This CFD-200 low loss cable’s insertion loss is 2.2dB and it has an impedance of 50 Ohms. Its sole purpose is to increase the length of the existing antenna connection cable.
The applicable subheading for the antennas (model #’s TL-ANT2408CL, TL-ANT2412D, TL-ANT2409A) will be 8517.70.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Telephone sets…; other apparatus for the transmission or 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”. The general rate of duty will be Free.
The applicable subheading for the antenna extension cable (model # TL-ANT24EC3S) will be 8544.20.0000, HTSUS, which provides for “Insulated (including enameled or anodized) wire, cable (including coaxial cable) and other insulated electric conductors, whether or not fitted with connectors; optical fiber cables, made up of individually sheathed fibers, whether or not assembled with electric conductors or fitted with connectors: Coaxial cable and other coaxial electric conductors”. The general rate of duty will be 5.3% ad valorem.
Effective July 6, 2018, the Office of the United States Trade Representative (USTR) imposed an additional tariff on certain products of China classified in the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), HTSUS. The USTR imposed additional tariffs, effective August 23, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(d), HTSUS. Subsequently, the USTR imposed further tariffs, effective September 24, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(f) and U.S. Note 20(g), HTSUS. For additional information, please see the relevant Federal Register notices dated June 20, 2018 (83 F.R. 28710), August 16, 2018 (83 F.R. 40823), and September 21, 2018 (83 F.R. 47974). Products of China that are provided for in subheading 9903.88.01, 9903.88.02, 9903.88.03, or 9903.88.04 and classified in one of the subheadings enumerated in U.S. Note 20(b), U.S. Note 20(d), U.S. Note 20(f) or U.S. Note 20(g) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees and charges that apply to such products, as well as to those imposed by the aforementioned Chapter 99 subheadings.
Products of China classified under subheading 8544.20.00, HTSUS, unless specifically excluded, are subject to the additional 10 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8544.20.0000, HTSUS, listed above.
The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading.
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 the 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 Steven Pollichino at firstname.lastname@example.org.
Steven A. Mack
National Commodity Specialist Division