CLA-2-85:OT:RR:NC:N4:410
Mr. George Ho
Leader Expedite
22930 Crenshaw Blvd.
Torrance, CA 90505
RE: The tariff classification of a robotic vacuum cleaner from China
Dear Mr. Ho:
In your letter dated May 26, 2020, you requested a tariff classification ruling. Pictures and product specifications were submitted with your request.
The subject merchandise is an automatic vacuum cleaner described as “Eufy RoboVac 30C”, which includes a vacuum cleaner (RoboVac 30C), boundary strips, a remote control, a charging base, an AC power adapter, a cleaning tool, an extra set of filters, 4 side brushes, 5 cable ties and a welcome guide. The vacuum cleaner is disk-shaped measuring approximately 12.8 inches in diameter and 2.85 inches in height with a 0.6 L receptacle.
The item is a Wi-Fi connected vacuum robot used to clean floors. It can be operated manually via remote control or in a “self-drive" mode which allows the machine to clean autonomously without human control. Voice control can be activated with the EufyHome app, and Amazon Alexa and the Google Assistant. The user can set boundary strips and the robotic vacuum only cleans certain areas.
The applicable subheading for the Eufy RoboVac 30C will be 8508.11.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Vacuum cleaners, parts thereof: With a self-contained electric motor: Of a power not exceeding 1,500 W and having a dust bag or other receptacle capacity not exceeding 20 l”. 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 8508.11.0000, HTSUS, unless specifically excluded, are subject to an additional 25 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 8508.11.0000, 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.
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 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 Michael Chen at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division