CLA-2-85:OT:RR:NC:N2:220
TARIFF: 8504.50.8000; 9903.88.03; 9903.01.24
Richard Ta
Odyssey International Services Inc.
305 Bridgepoint Drive Suite 150
St. Paul, MN 55075
RE: The tariff classification and country of origin of an inductive charger
Dear Mr. Ta:
In your letter dated March 24, 2025, you requested a tariff classification and country of origin ruling on
behalf of your client, Chug Inc.
The merchandise under consideration is referred to as the Smartwatch Charger (Charger), which is described
as an inductive-type charger consisting of a circular plastic molded housing, a magnetic charging module, a
printed circuit board assembly (PCBA), and a permanently affixed USB electrical cable with a USB Type C
connector on the end. The module housing, which you refer to as the C962 Module Top Cover, has a
concave surface to magnetically mate with a user’s smart watch for the purpose of inductively charging the
watch’s internal battery. In use, the Charger is plugged into a USB socket to receive power and a user’s
personal electronic device is wirelessly charged by placing it in alignment with the charging module. We
note that no information concerning retail packaging was provided in your request that describes how the
Charger is imported or if any additional devices are present at the time of entry. Consequently, this ruling
pertains only to the Charger, as described, and does not include a power adapter or other rectifying apparatus.
Based on the information provided, the charging module and the PCBA are manufactured in China, while the
housing, the electrical cable, numerous molded components, and the connector are sourced from Vietnam.
The assembly process is said to occur in Vietnam and consists of programming the C962 PCBA, soldering
the PCBA to the cable, inserting the C962 charging module into the plastic housing, and soldering the
individual cable wires to produce a functional inductive charging device.
Regarding tariff classification, you suggest the subject Charger is classifiable under subheading
8517.79.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Telephone
sets, including smartphones and other 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: Other”. We disagree. The
item concerned is an inductive charging cable, separate and distinct from the watch, and would not be
considered a part but rather an accessory to the watch. As heading 8517, HTSUS, does not have an accessory
provision, subheading 8517.79.0000, HTSUS would not be appropriate.
The applicable subheading for the Charger will be 8504.50.8000, HTSUS, which provides for “Electrical
transformers, static converters and inductors…: Other inductors: Other”. The general rate of duty will be 3%.
Pursuant to U.S. Note 31(b) to Subchapter III, Chapter 99, HTSUS, effective September 27, 2024, products
of China classified under subheading 8504.50.8000, 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 8504.50.8000, HTSUS, listed above.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 8504.50.8000, HTSUS, listed above.
When determining the country of origin for purposes of applying current trade remedies under Section 301,
the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619,
dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether
an article emerges from a process with a new name, character, or use different from that possessed by the
article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This
determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16
C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
Regarding the country of origin of the Charger, in our view, the assembly operations performed in Vietnam,
which consist of programming the C962 PCBA, inserting the C962 magnetic charging module and soldering
the wires, and soldering the C962 PCBA to the cable assembly, are neither complex nor do they substantially
transform the articles being assembled. Further, it is the opinion of this office that the C962 PCBA and
magnetic charging module establish the function of the device because they are the articles within the
assembly that are performing the inductive charging. Therefore, based upon the facts presented, the subject
Charger is considered a product of China for origin purposes at time of importation into the United States.
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 Karl Moosbrugger at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division