CLA-2-84:OT:RR:NC:N1:105
Amit Ghia
BodyTrace, Inc.
2150 N 1st St, Unit 469
San Jose, CA 95131
RE: The tariff classification of digital scales from China
Dear Mr. Ghia:
In your letter dated April 29, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The items under consideration are described as BodyTrace digital scales (model numbers BT007A and
BT007B), which are digital scales that include cellular connectivity, enabling automatic transmission of the
user’s weight data directly to a smart device or medical professional. The BT007A has a maximum weight
capacity of 440 pounds while the BT007B has a maximum weight capacity of 550 pounds. In addition to the
cellular connectivity, the user can also obtain the weight reading on an integrated LED display. The scales
measure 320 mm x 320 mm x 30 mm and weigh 1.9 kg. The scales are made of plastic, glass, and electronic
components, and are powered by three AA batteries.
In your letter, you suggest the classification of the scales to be within heading 8517, Harmonized Tariff
Schedule of the United States (HTSUS), which provides in relevant part 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)…”. In this case, the measurement data generated by
the scale is the core function of the product. It is the calculated measurement which is of interest to the user.
How that data gets to the end use device (i.e., wired connection or wirelessly) is a support or secondary
function. Without that measurement data, there is no need for the transmission function. Additionally, the
measurements are provided to the user on the integrated LED display. Therefore, classification under heading
8517, HTSUS, is precluded because the device concerned is used primarily to execute a measurement
function which would be beyond the scope on heading 8517, HTSUS.
Accordingly, the applicable subheading for the BodyTrace digital scales (model number BT007A and
BT007B) will be 8423.10.0010, Harmonized Tariff Schedule of the United States (HTSUS), which provides
for “Weighing machinery (excluding balances of a sensitivity of 5 cg or better), including weight-operated
counting or checking machines; weighing machine weights of all kinds; parts of weighing machinery:
Personal weighing machines, including baby scales; household scales: Digital electronic type. 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 8423.10.0010, 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 8423.10.0010, 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 Jason Christie at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division