CLA-2-85:OT:RR:NC:N2:120
Mark C. Hamilton, LCB
C.H. Robinson
4659 World Parkway Circle
St. Louis, MO 63134
RE: The tariff classification of a keypad from China
Dear Mr. Hamilton:
In your letter dated August 8, 2017 you requested a tariff classification ruling on behalf of your client, Security Equipment Corporation.
The merchandise under consideration is identified as the Fake Security Keypad, model number DKP-S11, which is described as a battery operated mountable keypad that resembles a home security system. The subject Keypad consists of a plastic housing, numbered buttons that are backlit, and two status indicators. The purpose of the Keypad is to give the illusion of a home security alarm system and you state that when the buttons are depressed, the Keypad emits a sound similar to what a functional security system keypad would make.
In your request you have proposed classification of the subject Keypad under subheading 8531.80.9051, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other electric sound or visual signaling apparatus. Heading 8531 provides for items that provide an audible or visual signal. The item concerned does not provide a signal nor is it capable of being used to provide a signal. A signal is a simple form of communication that is easily understood. A signal would alert the user to a change or indicate a specific event. This item does not communicate a change nor does it alert the user to a new or different condition or specific event. Based on the information heading 8531 would not be appropriate.
The applicable subheading for the Fake Security Keypad, model number DKP-S11, will be 8543.70.9960, HTSUS, which provides for; Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; Other machines and apparatus; …Other. The rate of duty will be 2.6 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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division