CLA-2-90:OT:RR:NC:N1:105
Payton Lenz
Pretaa, Inc.
400 Redland Ct., Suite 102
Owings Mills, MD 21117
RE: The tariff classification of a smart ring from China
Dear Mr. Lenz:
In your letter dated April 23, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The product under consideration is described as the QRing wearable smart ring and is constructed from
stainless steel or aluminum alloy. It contains embedded biometric sensors (including an accelerometer), has
Bluetooth connectivity, a 15-18 Mah lithium-ion battery, a memory chip to store the data, and is worn on the
user’s finger. The ring’s principal use is to gather personal health data related to cardiovascular and sleep
performance and transmit that information to a paired mobile device. The ring provides the user’s heart rate,
blood oxygen saturation, skin surface temperature, sleep duration and stages, and step and motion detection.
The data is stored locally on the ring and transferred when the user syncs it via the QRing mobile application.
The device does not contain a display, microphone, speaker, SIM, or Wi-Fi module. Further, the product does
not offer telecommunication functions such as internet access, calling, or GPS tracking. Each ring is
packaged with a USB or magnetic charging case, user manual, and a QR code linking to the app store. The
ring comes in various sizes ranging from 17.4mm to 23.1mm, weighs roughly 3.6 grams, and can be
purchased in gun color, silver, or rose gold.
Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance
with the General Rules of Interpretation (GRI’s). GRI 1 provides that the classification of goods shall be
determined according to the terms of the headings and any relevant section or chapter notes. In the event the
articles cannot be classified solely on the basis of GRI 1, GRI’s 2 through 6 may be applied in order, as
appropriate. The Explanatory Notes to the HTSUS, while not legally binding, may also be consulted to aid in
classification. As the QRing does more than keep count of heart rate, steps taken, oxygen saturation, etc., the
device would not be classified, by operation of GRI 1, as counting devices of heading 9029, HTSUS, nor as a
communication device of heading 8517 HTSUS. The QRing is considered to be a composite good within the
meaning of GRI 3. Goods classifiable under GRI 3(b) shall be classified as if they consisted of material or a
component which gives them their essential character. The Explanatory Note to GRI 3(b)(VIII), states that
the factors which determine essential character will vary between different kinds of goods. It may, for
example, be determined by the nature of the materials or components, its bulk, quantity, weight or value, or
by the role of a constituent material in relation to the use of the goods. GRI 3(c) states that when the essential
character of a composite good cannot be determined, classification is based on the heading that occurs last in
numerical order among those which equally merit consideration. Inasmuch as no one component imparts the
essential character to the subject composite item, GRI 3(b) does not apply. It is the opinion of this office that
the communication ability in heading 8517, HTSUS, and tracking of the heart rate and steps in heading 9029,
HTSUS, merits equal consideration to the accelerometer in heading 9031, HTSUS. Therefore, classification
will be determined based on the competing heading that occurs last in numerical order. GRI 3(c) noted.
Please note that we find the QRing to be similar to the Samsung Galaxy Smart Ring both in functionality and
appearance. Customs and Border Protection classified the ring in New York Ruling Letter N340510 (dated
June 10, 2024) in subheading 9031.80.8085, HTSUS.
Accordingly, as you suggest in your letter, the applicable subheading for the QRing will be 9031.80.8085,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Measuring or checking
instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors;
parts and accessories thereof: Other instruments, appliances and machines: Other: Other.” The general rate of
duty will be free.
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 9031.80.8085 HTSUS, listed above.
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 9031.80.8085, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 9031.80.8085, 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 9903.88.01 in
addition to subheading 9031.80.8085, 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 trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, 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 and
https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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 Jason Christie at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division