CLA-2-90:OT:RR:NC:N1:105
Maria Lohnes
DoubleDay Acquisitions, LLC dba CSafe
675 Gateway Blvd
Monroe, OH 45050
RE: The tariff classification of data loggers from China
Dear Ms. Lohnes:
In your letter dated May 9, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The first item under consideration is described as the Multi-Use RLT V55 Plus (Part #160-0003), which is a
reusable real-time data logger with global 4G/5G LTE connectivity. It uses embedded cellular modems and
SIM cards to connect autonomously to the internet and transmit collected data. The device allows users to
verify ambient temperature using the internal device (-30°C to +70°C), external temperature using the probe
routed into the package or crate (-200°C to +100°C), humidity (5% RH to 95% RH), shock (1g to 8g), light
(0 Lux to 52,000 Lux), tilt (0° to 180°), and GPS location. It is equipped with an auto-flight safe mode that
suspends cellular activity during flights. The data logger automatically transmits all data to the CSafe
Connect cloud platform via cellular networks. The device measures 105 mm by 65 mm by 16.9 mm and
weighs 130 grams.
The second item under consideration is described as the Single-Use RLT V5J Plus (Part #160-0004), which is
a single-use version of the Multi-Use RLT V55 Plus. It also contains an integrated 4G/5G LTE cellular
module and uses embedded cellular modems and SIM cards to connect autonomously to the internet and
transmit collected data. The device allows users to verify ambient temperature using the internal device
(-30°C to +70°C), external temperature using the probe routed into the package or crate (-200°C to +100°C),
humidity (5% RH to 95% RH), shock (1g to 8g), light (0 Lux to 52,000 Lux), tilt (0° to 180°), and GPS
location. It is equipped with an auto-flight safe mode that suspends cellular activity during flights. The device
measures 105 mm by 65 mm by 16.9 mm and weighs 130 grams.
The third item under consideration is described as the TracSafe RLT t72 PRO.1 Meter Probe (Part
#160-0001-01), which is a real-time wireless transmission device featuring 4G/5G LTE cellular connectivity.
The device allows users to verify ambient temperature using the internal device (-30°C to +70°C), external
temperature using the probe routed into the package or crate (-200°C to +100°C), humidity (5% RH to 95%
RH), shock (1g to 16g), light (0 Lux to 52,000 Lux), tilt (0° to 180°), and GPS location. It is equipped with
an auto-flight safe mode that suspends cellular activity during flights. The device measures 114 mm x 76.0
mm x 27 mm and weighs 200 grams.
In your letter, you suggest the classification of the Multi-Use RLT V55 Plus (Part #160-0003), the
Single-Use RLT V5J Plus (Part #160-0004), and the TracSafe RLT t72 PRO.1 Meter Probe (Part
#160-0001-01) to be under 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)…”. We disagree. We find the core function of each sensor to be the measuring/checking. 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 the 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 each of the
environmental sensors are used primarily to execute a measurement function which would be beyond the
scope on heading 8517, HTSUS.
Classification under the HTSUS is made in accordance with the General Rules of Interpretation (GRIs). 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,
GRIs 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. The sensors listed above are considered to be
composite goods within the meaning of GRI 3. Goods classifiable under GRI 3(b) shall be classified as if
they consisted of the 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 items, GRI 3(b) does not apply.
It is our opinion that the Multi-Use RLT V55 Plus, the Single-Use RLT V5J Plus, and the TracSafe RLT t72
PRO.1’s temperature and humidity reading ability in heading 9025, HTSUS, merits equal consideration to the
shock sensing ability in heading 9031, HTSUS, and the GPS of Chapter 85. Therefore, the classification for
the three devices will be determined based on the competing heading that occurs last in numerical order. GRI
3(c) noted.
Accordingly, the applicable subheading for the Multi-Use RLT V55 Plus (Part #160-0003), the Single-Use
RLT V5J Plus (Part #160-0004), and the TracSafe RLT t72 PRO.1 Meter Probe (Part #160-0001-01) will be
9031.80.8085, 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. 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.
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.
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