CLA-2-85:OT:RR:NC:N2:209
Ryan Supek
Import/Export Analyst
TE Connectivity Corporation
2800 Fulling Mill Road
Middletown, PA 17057
RE: The tariff classification of a PCB Antenna from China
Dear Mr. Supek:
In your letter dated March 26, 2020, you requested a tariff classification ruling.
The item concerned is referred to as the Penta Band PCB Antenna (part # 1513317-1). This antenna is utilized in various devices needing wireless connectivity (i.e. smart meters, wearable devices, security devices, and other Internet of Things devices).
This antenna is created using a printed circuit board manufacturing process which creates a copper antenna pattern on a laminated substrate/board. It is a surface mount component that, in use, would be solder onto a printed circuit board assembly. This component does not incorporate any other electrical elements (i.e. no active nor passive elements) or components (i.e. no modulator/demodulator, amplifier, signal generator, filters, switches, modems, routers, etc.). This antenna is a passive device that must be connected to a transmitter/receiver module to function.
The applicable subheading for the Penta Band PCB Antenna (part # 1513317-1) will be 8517.70.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Telephone sets, including telephones for cellular networks or for other wireless networks; 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 rate of duty will be Free.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8517.70.00, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 8517.70.0000, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division