CLA-2-85:OT:RR:NC:N2:212
Jeongeun Kim
Cusan Customs Service Incorporation
#309, 35, Magokjungang 2-ro, Gangseo-gu
Seoul 07806
South Korea
RE: The tariff classification of a learning robot from Korea
Dear Mr. Kim:
In your letter dated May 20, 2025, you requested a tariff classification ruling on behalf of Unit Company, Inc.
The merchandise under consideration is identified as the PYBOT coding education robot. The subject item is
comprised of a plastic body within which is various electronics including a programmable Raspberry Pi and a
processor chip. Additionally, the robot contains a DC encoder motor to allow movement as well as an
embedded camera, speaker, microphone and LED screen. The front of the robot is designed to resemble a
face complete with expressive eyes and mouth.
The learning robot is meant to be wirelessly connected to a laptop or personal computer and allows for a
child to input and learn certain code through the Python coding language. The student can program the device
through hands-on projects including autonomous driving, line tracing, maze solving, among others. You state
that the robot is primarily used in the classroom environment.
In your request, you suggest that the correct classification for the subject learning robot is subheading
9503.00.0090, Harmonized Tariff Schedule of the United States (HTSUS). We disagree.
Heading 9503, HTSUS, is a principal use provision per the terms of the heading. As such, we look to
Additional Rule of Interpretation 1(a), which states that principal use “is to be determined in accordance with
the use in the United States at, or immediately prior to, the date of importation, of goods of that class or kind
to which the imported goods belong, and the controlling use is the principal use.” In addition, court cases
have set precedent for considering additional factors, including the general physical characteristics, the
expectation of the ultimate purchaser, channels of trade, environment of sale (such as accompanying
accessories, manner of advertisement and display), Usage, if any, in the same manner as merchandise which
defines the class, economic practicality of so using the import and recognition in the trade of this use.
It is our view that the subject robot is primarily used to perform educational and learning activities. Any
amusement experienced by the child is therefore meant to facilitate the learning process, which makes the
system a better learning tool. As the function of the PYBOT is to educate and not to amuse the child,
classification within heading 9503, HTSUS, is not appropriate in this case.
The applicable subheading for the PYBOT coding education robot will be 8543.70.9301, HTSUS, which
provides for “Electrical machines and apparatus, having individual functions, not specified or included
elsewhere in this chapter; Portable interactive electronic education devices primarily designed for children.”
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
8543.70.9301, 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 Luke LePage at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division