CLA-2-85:OT:RR:NC:N2:212
Kathy Alexander
Good Life, Inc.
624B Wagon Trail Drive
Jacksonville, OR 97530
RE: The tariff classification of an ultrasonic dog barking control device from China
Dear Ms. Alexander:
In your letter dated April 29, 2025, you requested a tariff classification ruling.
The merchandise under consideration, identified as the Dog Silencer Max, is described as an anti-bark device
for dogs. It uses high frequency ultrasonic sound that is powerful enough to quiet the dogs within the range of
300 feet from the device. The device consists of an audible speaker, ultrasonic speaker, LED indicator light,
microphone enclosed in a black plastic case and it comes with a remote control for the user to activate the
ultrasonic sound manually. The device is powered by either the included AC adapter or battery.
In use, the device is placed indoors or outdoors near the area where the dogs will be present. Once it is set up,
the device will automatically emit the ultrasonic sound when it detects dogs barking within a 75ft range and
the user can activate it manually with a remote control when the dogs are in the range of between 75 feet and
300 feet. The ultrasonic sound is inaudible to humans but is broadcast in a range only heard by a dog, which
they will find unpleasant. Through repetition, dogs will associate their barking with the high-pitched
ultrasonic sound, which will reduce the barking behavior.
In your submission, you suggest that the device is correctly classified under 8517.62.0090, Harmonized
Tariff Schedule of the United States (HTSUS). We disagree.
Heading 8517, HTSUS, provides, in relevant part, for “…other apparatus for the transmission of 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) …” The item concerned does not have the function of transmitting voice, images
or other data as it merely generates ultrasonic sounds. Therefore, subheading 8517.62.0090, HTSUS, is not
applicable.
You also suggest classification under 8531.80.9041, HTSUS, which provides for “Electric sound or visual
signaling apparatus (for example, bells, sirens, indicator panels, burglar or fire alarms) ...Other sound
signaling apparatus.” Again, the subject device is designed to detect barking and emit ultrasonic sounds that
only dogs can hear. It does not have the function of signaling as described within the suggested heading. As
such, classification under subheading 8531.80.9041, HTSUS, is not applicable.
The applicable subheading for the Dog Silencer Max will be 8543.70.9860, 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”. The rate of duty will be 2.6% ad
valorem.
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 8543.70.9860, 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. At this time products from all 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
8543.70.9860, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8543.70.9860, 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 8543.70.9860, 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
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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