CLA-2-90:OT:RR:NC:N3 135
Brooke Cook
Gentex Corporation
600 N. Centennial St. Zeeland, MI 49464
RE: The tariff classification of an Optical Module from China
Dear Ms. Cook:
In your letter dated December 16, 2024, you requested a tariff classification ruling. A sample received on January 2, 2025 was examined and will be returned.
The product under consideration is an Optical Module for eSight Go (Gentex SKU# 625-2310-000) consisting of a magnesium frame, two Micro OLED displays, one right eye optic, one left eye optic, 4 screws, and two graphene tapes. The frame is the mechanical base that other components are attached to. The displays are high resolution, compact displays that use light emitting elements to emit light when an electrical charge is applied. The optics have multiple surfaces to magnify, reflect, and focus light for the user to view the projected images from the Micro OLED displays. On the back of the optics, there is a black opaque coating with a reflective material that acts as a reflective surface to direct the light back toward the user. The screws attach the optics to the frame and the graphene tapes adhere the Micro OLED displays to the frame. The function of the tapes is to transfer and dissipate heat from the displays to the frame. After importation into the United States, the Optical Module is assembled into a finished good, the eSight Go wearable device. In addition to the Optical Module, the finished device is comprised of the following parts: a camera, a signal processing module, a controller circuit board, battery, plastic lenses and/or optional corrective lenses, a nose piece, and plastic housings.
You explain that the Optical Module is specifically designed and engineered to be used in the eSight Go wearable device and is different from typical optical modules found in Augmented Reality (AR) glasses because the user cannot see the real world through the back of the lenses. Images captured by the camera are corrected for the user by software and controls. The Mirco OLED displays project the light and image downward onto a reflective material within the lens, which reflects the display 90 degrees onto the mirror that is protected by an opaque black surface of the Right/Left Eye Optics. On the inside of the black surface is a reflective material that acts as a mirror. The user looks through the Right/Left Eye Optics to view the image. You state the eSight Go wearable device helps people with significant central vision loss and legal blindness achieve enhanced vision. The eSight Go is the next generation and a similar design to the eSight 4 Electronic Eyewear Kit, which is the subject of Customs Ruling N312578.
The applicable subheading for the Optical Module will be 9021.90.8100, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[o]rthopedic appliances, including crutches, surgical belts and trusses; splints and other fracture appliances; artificial parts of the body; hearing aids and other appliances which are worn or carried, or implanted in the body, to compensate for a defect or disability; parts and accessories thereof: [o]ther: [o]ther.” The rate of duty will be free.
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 at https://hts.usitc.gov/.
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 and Border Protection 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, please contact National Import Specialist Fei Chen at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division