CLA-2-85:OT:RR:NC:N2:212
Blanca Graves
Samsung Electronics America, Inc.
6625 Excellence Way
Plano, TX 75023
RE: The tariff classification of an E-Paper Sign Device from Vietnam
Dear Ms. Graves:
In your letter dated June 2, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as the Electronic Paper Display (EPD) Smart Sign, part
number LH32EMDIBGBXEN, which you describe as an e-paper display. The subject device is comprised of
a 32-inch EPD display, control printed circuit board assembly (PCBA), and a timing control board within a
metal chassis. The device further incorporates Bluetooth and Wi-Fi connection capabilities and is powered by
an internal rechargeable battery.
The subject Smart Sign is used in commercial environments in order to display prices, promotions, and
advertisements directly on the e-paper screen in order to replace paper promotional materials or signage. The
user can install new content via the Bluetooth and/or Wi-fi connection. We note that the device is not capable
of displaying video or sound.
In your request, you suggest two classifications for the subject smart sign. The first is under subheading
8531.80, Harmonized Tariff Schedule of the United States (HTSUS). To this suggestion, we disagree.
Heading 8531, HTSUS, covers only those displays that are limited by design and/or principal use to signaling
or indicating specific state/condition. The instant article is not used for signaling or warning the user with a
specific status or condition but rather it is used to display advertising materials including menus and price of
goods/services in a retail setting. Furthermore, the Explanatory Notes to heading 8531 excludes electric
advertising signs. Therefore, classification under subheading 8531.80, HTSUS, is inappropriate.
The next suggestion for the subject device is under heading 8543, HTSUS. To this suggestion, we agree.
The applicable subheading for the EPD Smart Sign, part number LH32EMDIBGBXEN, 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: Other: Other.” The general rate of duty will be 2.6% ad valorem.
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.
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