CLA-2-90:OT:RR:NC:N1:105
Yuichiro Nozaki
Sanyo Chemical America
17 Arentzen Blvd., Suite 206
Charleroi, PA 15022
RE: The tariff classification of a sensor module from Japan
Dear Mr. Nozaki:
In your letter dated May 5, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The item under consideration is described as the 5Q-SSM sensor module, which is a Quartz Crystal
Microbalance (QCM)-type smell sensor that detects changes in mass due to the adsorption/desorption of odor
molecules onto a membrane surface. These changes are translated into resonance frequency shifts (in Hz) of
the quartz crystal unit and output as digital data. The sensor can be embedded into other articles or used as a
standalone device. The 5Q-SSM measures 20mm by 28mm by 2.84mm and weighs 10g. It is imported with
the sensor (including 5 membranes with different chemical affinity), a USB converter board, an optional
protective case, a USB flash drive with software, and a micro-USB cable.
The sensor module includes a set of five standardized membranes designed for general odor identification
(such as ethanol, toluene, kerosene, etc.). Custom sets tailored for specific applications are also available. The
sensor is used for proof-of-concept (POC) evaluation and may be embedded in broader systems or consumer
devices for smell detection. The device is intended for Internet of Things (IoT) home monitoring devices
(e.g., wall outlets that detect odors), smart agriculture (e.g., detecting gas emissions from crops), odor
detection systems in industrial or consumer use, environmental and ambient monitoring, quality control, and
healthcare.
The applicable subheading for the 5Q-SSM sensor 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 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
9031.80.8085, HTSUS, listed above.
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 Jason Christie at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division