CLA-2-90:OT:RR:NC:N1:105
Nathan Besh
NateChrony
7 Broughton Place
Davidson 2085
Australia
RE: The tariff classification and country of origin of a smart target
Dear Mr. Besh:
In your letter dated May 19, 2025, you requested a tariff classification and country of origin determination
ruling.
The item under consideration is described as the NateChrony SmartTarget, which is a small electronic device
that is attached to the back surface of a shooting target. When the target is struck with an object such as a
bullet, baseball, golf ball, etc., the device will detect the movement using a built-in 3-axis accelerometer and
3-axis gyroscope. By analyzing the movement, the SmartTarget can detect being hit and include the rough
location of the hit. The SmartTarget can be mounted to any target, however, you indicate a free-moving
target such as a hanging gong is highly recommended as it allows the device to move freely in a left-right and
up-down direction. There are holes in the SmartTarget housing which can be used to screw the device to the
target surface, or the user can utilize double-sided tape. If the SmartTarget is used for hit placement, it is
mounted with the green connection block placed at the top.
The SmartTarget is designed with a microprocessor board that includes a movement sensor. The device is
always analyzing the movement of the sensor, and when change is detected, the shot is registered. This
information is then transmitted over Wi-Fi to the user’s smart device. External, optional accessories such as
lighting systems or external connector boards can also be triggered to show a visual indication of the hit.
The applicable subheading for the NateChrony SmartTarget 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.
In your letter, you also requested a country-of-origin determination. In China, the circuit board is created via
an automation method with components from various countries including China, Japan, Taiwan, and Korea.
This includes pick-and-place machines and automated soldering. The Taiwanese processor accounts for 69%
of the circuit board cost while the Malaysian inertial measurement unit (IMU) accounts for 16%. The small
number of remaining Chinese and Japanese components make up the remaining value. The completed board
has all of the necessary physical components to operate, however, it cannot function without the addition of
the Australian developed software. The software is also loaded onto the board in Australia. The case is 3D
printed in Australia from Australian sourced materials and is designed to hold and protect the circuit board.
The Chinese produced circuit board is then placed into the Australian made case and the lid is screwed on.
The additional accessories are also assembled in Australia from imported components from Japan and China.
These accessories include external light assemblies, connectors, and wiring looms that are cut to size,
soldered, and affixed to the various components in Australia. All of these accessories are then connected to
the circuit board. Finally, the unit is placed into the Australian produced packaging and sealed.
When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter H301619, dated November 6, 2018. The test for determining whether a
substantial transformation will occur is whether an article emerges from a process with a new name,
character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v.
United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See
National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
Regarding the country of origin of the NateChrony SmartTarget, it is our opinion that the assembly process
performed in Australia is not considered complex and does not constitute a substantial transformation. The
circuit board is complete with all of its components, other than the software, when it is imported from China.
Adding the circuit board to the case only requires simple assembly. Additionally, the software is easily
downloaded to the memory of the circuit board. Therefore, to determine the country of origin of the
SmartTarget, we rely on the origin of the finished circuit board assembly, which is the essential component
of the SmartTarget. It is the finished circuit board assembly that contains the accelerometer and gyroscope,
which is performing the measuring function. These are complete and unchanged when finally assembled into
the case in Australia. Accordingly, the country of origin of the NateChrony SmartTarget will be China, which
is where the finished circuit board assembly is manufactured.
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