CLA-2-85:OT:RR:NC:N2:209
Elizabeth Lowe
Venable LLP
600 Massachusetts Ave., NW
Washington, DC 20001
RE: The tariff classification of an LCD home automation hub from Vietnam
Dear Ms. Lowe:
In your letter dated April 14, 2025, you requested a tariff classification ruling.
The item concerned is referred to as “The Vivint Smart Hub Pro.” This device is an LCD control panel that
wirelessly connects to various smart home devices and security systems within the Vivint ecosystem. It
features a user-friendly touchscreen interface that allows users to monitor and control security sensors,
cameras, door locks, thermostats, and other connected devices. The panel uses prominent icons to deliver
critical status updates, alerts, and event notifications. It allows access to activity history, video and audio
communication, security system arming and disarming, configuration and operation of connected devices,
and emergency features.
The key features of the Smart Hub Pro are as follows:
7’’ capacitive, color liquid crystal display (“LCD”) touchscreen.
Built-in smoke, carbon monoxide (CO), and glass break monitoring.
Built-in speakers and microphones support two-way voice communication with Vivint’s 24/7
professional monitoring centers.
View live video and recorded clips if cameras are installed.
85dB siren
Status LED to indicate whether the alarm system is armed or disarmed.
Dual-band Wi-Fi and LTE cellular connectivity.
Built-in Z-wave technology enabling HVAC, appliance, lighting, and security control.
Built-in encrypted cellular communication unit.
Remote management from a computer or internet-enabled phone.
24-hour backup rechargeable battery.
345mHz radio interface links sensor signals back to the panel.
The panel communicates with users and Vivint’s 24/7 professional monitoring centers via cellular and
internet connections and interacts with home security and safety devices (e.g., smoke detectors) through a
345 MHz radio frequency. It controls home automation devices (e.g., door locks, thermostats) by Z-waveTM
(910Mhz) radio and communicates with security cameras using Wi-Fi and Ethernet.
The Smart Hub Pro incorporates internal sensors that are used for detecting various home security
occurrences (i.e. glass breakage, smoke, carbon monoxide (CO) and proximity sensors) When triggered,
these sensors alert the user and provide options to report a real emergency, indicate a false alarm, or connect
with the monitoring center if they are uncertain.
The Smart Hub Pro is used to display limited information about home automation and security devices, such
as signaling to users when these devices detect a specific event set by the users. It primarily uses easily
recognizable icons rather than text to convey critical status updates, alerts, and event notifications. The Smart
Hub Pro allows users to configure and manage various connected devices and set personalized audio alerts
and notifications for specific conditions. In addition to the LCD indicator panel the Smart Hub Pro also
incorporates an 85dB siren triggered by events such as a potential security breach, fire, or carbon monoxide
risk.
The “Vivint Smart Hub Pro,” meets the definition of a composite machine as it acts as a data
transmission/reception hub, and a sound/visual 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 the functions (data transmission/reception and audio/visual signaling) 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 Smart Hub Pro,” 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 Smart Hub Pro,” will be 8531.20.0020, 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):
Incorporating LCD’s.” 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 8531.20.0020, 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