CLA-2-85:OT:RR:NC:N2:209
Elizabeth Lowe
Venable LLP
600 Massachusetts Ave., NW
Washington, DC 20001
RE: The tariff classification of a security hub from Vietnam
Dear Ms. Lowe:
In your letter dated April 7, 2025, you requested a tariff classification ruling on behalf of your client Vivint
LLC.
The item concerned is referred to as Vivint’s Security Hub, model # VS-EH1000-001. This security Hub
allows users to monitor and manage their smart home automation devices within the Vivint ecosystem. The
security hub acts as a central control unit for the installed Vivint system and provides critical status
information and alerts to the user’s mobile app and local control devices. The panel supports detection
devices such as perimeter sensors (e.g., door and window and motion detection sensors), doorbell cameras,
wireless door locks, and thermostats.
The primary features of the Security Hub are as follows:
Status LED uses colored lights to display the system’s state. For example, a solid green light indicates
ready-to-arm, a blinking green light indicates exit delay, a solid orange light represents armed, a
blinking orange light signals entry delay, a blinking red light indicates an alarm event, a solid white
light means not ready-to-arm, and a repeating fade-in-and-out red light indicates a system error.
100dB siren triggered by events such as a potential security breach.
Tamper switch that reports if the battery door is removed.
UL1023 household burglary alarm system certification.
Sensor and device communication via a Z-WaveTM (908 MHz and 916 MHz) radio.
Encrypted LTE cellular data radio for backup communication during power and internet outages.
Ethernet connection to broadband internet.
4-hour backup rechargeable battery.
AC power supply.
Size 5.6 in. x 4.3 in. x 1.5 in.
The security hub does not incorporate a screen/monitor, built-in touchscreen, or physical buttons. It serves as
a processing hub that enables users to utilize a mobile app as their primary interface for controlling and
monitoring home automation and security and receiving alert notifications. The security hub does incorporate
LED status lights that provide notification of status to the user. The hub communicates with customers and
Vivint’s 24/7 monitoring centers via cellular and internet connections and with home security devices
through Z-Wave™ radio (908 MHz and 916 MHz). Additionally, the security hub is used to control home
automation devices via Z-Wave™ radio and connects with security cameras using an Ethernet connection to
the user’s broadband internet.
As stated within the submitted ruling request documentation, the security hub is used primarily for
“monitoring” and “signaling” functions, as it features LEDs (e.g., red, orange, green, white, or blinking) to
indicate the system’s status, such as armed, disarmed, active alarm, or error condition. The product’s
“monitoring” and “signaling” function is used to notify users of events detected by connected home
automation and security devices. In addition to the LED status/signal lights the hub incorporates a 100dB
siren that can be triggered by events such as a potential security breach.
The security hub also facilitates a communication link between various home automation devices (including
a doorbell camera, thermostat, lock, and sensors) and manages communication among them nearly
simultaneously through various logic. The hub acts as a type of router allowing the interconnectivity between
various home automation devices and the internet or home network. It receives, converts, and transmits
signals or data between the various home automation components and the internet or home network. The
various home automation devices cannot operate within the network without the use of the security hub.
The “Vivint Security Hub,” model # VS-EH1000-001, meets the definition of a composite machine as it acts
as a data transmission/reception hub and also as an indicator pane/signaling device. The classification of
composite machines is governed by Note 3 to Section XVI, HTSUS, which states, in relevant part, that
“machines designed for the purpose of performing two or more complementary or alternative functions are to
be classified as if consisting only of that component or as being that machine which performs the principal
function.” In addition, General Explanatory Note (VI) to Section XVI states, with respect to multi-function
machines and composite machines, that where it is not possible to determine the principal function and
where, as provided in Note 3 to Section XVI, the context does not otherwise require, it is necessary to apply
General Rule of Interpretation (GRI) 3(c). GRI 3(c) requires classification in the last heading from among
those which equally merit consideration.
In this case, it is our opinion that both the data transmission/reception function and the signaling function are
of equal merit. The two headings which merit equal consideration are heading 8517, HTSUS, which provides
for “…; 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)…” and heading
8531, HTSUS, which provides for “Electric sound or visual signaling apparatus (for example, bells, sirens,
indicator panels, burglar or fire alarms), other than those of heading 8512 or 8530; parts thereof.” As there is
no one principal function, the “Vivint Security Hub, model # VS-EH1000-001,” is classifiable in accordance
with GRI 3 (c), within heading 8531, HTSUS, as that is the heading to appear last in the tariff.
The applicable subheading for the “Vivint Security Hub, model # VS-EH1000-001,” will be 8531.20.0040,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric sound or visual
signaling apparatus (for example, bells, sirens, indicator panels, burglar or fire alarms), other than those of
heading 8512 or 8530; parts thereof: Indicator panels incorporating liquid crystal devices (LCD's) or light
emitting diodes (LED): Other.” The general rate of duty will be Free.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. ?Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to
subheading 8531.20.0040, HTSUS, listed above.?
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 Steven Pollichino at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division