CLA-2-90:OT:RR:NC:N1:105
Yanjun Lu
Netatmo
73 Rue de Sèvres
Boulogne Billancourt, 92100
France
RE: The tariff classification of the Netatmo Carbon Monoxide Detector from China
Dear Mr. Lu:
In your letter dated October 8, 2020, you requested a tariff classification ruling.
The item under consideration is described as the Netatmo Carbon Monoxide Detector (item # NCO01), which consists of two plastic shells, a metal grid and an electronic board. The electronic board is composed of a carbon monoxide sensor, a buzzer, several microcontrollers and two soldered lithium batteries. In operation, the detector will analyze the parts per million (PPM) of carbon monoxide and sound an alarm if the levels surpass the EN 50291 standard. The PPM measurement is not displayed on the detector. Instead, the user utilizes a smart device to obtain the PPM readout. The device measures 23 millimeters thick, 100 millimeters by 100 millimeters wide and is installed in rooms where the risk of carbon monoxide is high. The Netatmo Carbon Monoxide Detector is packaged with mounting screws and plugs, a wall bracket and a user manual.
The applicable subheading for the Netatmo Carbon Monoxide Detector (item # NCO01) will be 9027.10.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Instruments and apparatus for physical or chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke analysis apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion, surface tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound or light (including exposure meters); microtomes; parts and accessories thereof: Gas or smoke analysis apparatus: Electrical.” 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 9027.10.2000, 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., 9903.88.02, in addition to subheading 9027.10.2000, 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 Jason Christie at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division