CLA-2-85:OT:RR:NC:N2:220
Rodolfo Salinas
Infinite Electronics
301 Leora Ln.
Lewisville, TX 75056
RE: The tariff classification of an adapter kit from China
Dear Mr. Salinas:
In your letter dated March 26, 2024, you requested a tariff classification ruling.
The merchandise under consideration is identified as the Modular Adapter, DB25 Male / Dual RJ45 (8x8) Jack (Adapter), PN RA2588M, which is described as a disassembled electrical connector having a plastic housing with two female RJ45 sockets on one side, and a male DB25 connector on the other side. Based on the information provided, the two connectors are not attached at importation as each RJ45 electrical conductor extends from the back as a wire and male pin. In use, the end user determines the desired pinout on the DB25 connector by inserting the pin into the appropriate location according to their specific design. Once the pins are inserted, the two connectors are joined together with the screw posts.
In your request, you suggest the Adapter is properly classified under subheading 8536.69.4040, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. The subject kit consists of two types of electrical connectors, one being a male D-sub and the other type is female RJ45. As the connector is not intended to be soldered onto a printed circuit board, but rather cables are inserted on either side of the Adapter, subheading 8536.69.4040, HTSUS, is not appropriate.
The applicable subheading for the Modular Adapter, DB25 Male / Dual RJ45 (8x8) Jack, PN RA2588M, will be 8536.69.8000, HTSUS, which provides for “Electrical apparatus…for making connections to or in electrical circuits…: Lamp-holders, plugs and sockets: Other: Other.” The general rate of duty will be 2.7 percent ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8536.69.8000, 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 8536.69.8000, 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, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at the following addresses:
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions https://www.cbp.gov/trade/remedies/301-certain-products-china
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.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
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