CLA-2-85:OT:RR:NC:N2:212
Landon McCoy
Chaos Audio
7543 Holley Cir
Panama City Beach, FL 32408
RE: The tariff classification of an effects pedal from China
Dear Mr. McCoy:
In your letter dated April 15, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as the Chaos Audio Stratus effect pedal. The subject
device is constructed of a Printed Circuit Board Assembly (PCBA), which contains an ARM Central
Processing Unit (CPU), within a metal enclosure. On the outside of the enclosure is an LED light strip, rotary
encoder switch, and foot switch. On one side of the device is an audio out jack while the other has an audio
input jack. The effect pedal incorporates a USB-C port as well as a 9 Volt power port.
In use, a guitar is connected via the audio input and a speaker or amplifier is connected through the output.
The user connects the device, via Bluetooth, to their smartphone in order to load various guitar effects,
including reverb, distortion, modulation, and others onto the pedal. Once the effects are loaded onto the
device, the user can choose the appropriate one and turn the effects on and off via the rotary encoder and/or
foot switch. The audio signal is then sent from the guitar, through the effect pedal and is heard out of the
amplifier or speaker.
In your request, you suggest the subject effect pedal is properly classified under subheading 8471.41.01,
Harmonized Tariff Schedule of the United States (HTSUS). We disagree.
While the device incorporates some processing capabilities, mainly audio processing sound effect functions
such as looping, distortion, reverb, and more, it is not considered an automatic data processing machine as
provided for under Note 6 to Chapter 84, HTSUS. Further, the device meets the common and commercial
meaning of a special effects pedal, the function of which has been deemed to be accurately classified under
heading 8543, HTSUS.
The applicable subheading for the Chaos Audio Stratus effect pedal will be 8543.70.9820, HTSUS, which
provides for “Electrical machines and apparatus, having individual functions, not specified or included
elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other: Other: Special effects
pedals for use with musical instruments.” The general rate of duty will be 2.6% ad valorem.
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. 9903.01.63, in addition to
subheading 8543.70.9820, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8543.70.9820, 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., 9903.88.02,
in addition to subheading 8543.70.9820, 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 Section 301 trade remedy, you may refer to the relevant parts of the USTR and
CBP websites, which are available at:
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 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 Luke LePage at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division