CLA-2-84:OT:RR:NC:N2:220
M. Jason Cunningham
Sonnenberg & Cunningham PA
780 Fifth Ave South
Naples, FL 34102
RE: The tariff classification of the iConnect tablet accessories from China
Dear Mr. Cunningham:
In your letter dated June 6, 2025, you requested a tariff classification ruling on behalf of your client, Dana
Innovations a/k/a Sonance.
The first item under consideration is identified as the CONNECT PRO Case Air11 M3 BK, SKU 72324,
which is described as a plastic housing incorporating an integrated wireless charging module on the rear, a
USB-C plug integrated into the interior bottom, and an external dock connector on the rear. In use, a tablet
personal computer (PC) is mounted within the docking case and users receive interconnection through the
external dock connector, while facilitating the wireless charging via the charging module.
The second item under consideration is identified as the CONNECT PRO Case iPadA16 BK-V3, SKU
72447, which is described as a plastic housing incorporating an integrated wireless charging module on the
rear, a USB-C plug integrated into the interior bottom, and an external dock connector on the rear. In use, a
tablet PC is mounted within the docking case and users receive interconnection through the external dock
connector, while facilitating the wireless charging via the charging module.
The third item under consideration is identified as the C-PRO UTILITY CASE 11PRO M4 GN, SKU 72494,
which is described as a plastic housing incorporating an integrated wireless charging module on the rear, a
USB-C plug integrated into the interior bottom, a top bezel cover, and an external dock connector on the
rear. In use, a tablet PC is mounted within the docking case, the bezel is fastened in place to secure the
device, and users receive interconnection through the external dock connector, while facilitating the wireless
charging via the charging module.
The fourth item under consideration is identified as the CONNECT PRO Case iPad A16 BK, SKU 72340,
which is described as a plastic housing incorporating an integrated wireless charging module on the rear, a
USB-C plug integrated into the interior bottom, and an external dock connector on the rear. In use, a tablet
PC is mounted within the docking case and users receive interconnection through the external dock
connector, while facilitating the wireless charging via the charging module.
In your letter, you suggest the tablet accessories are properly classifiable under subheading 8473.30.5100,
Harmonized Tariff Schedule of the United States (HTSUS). We agree.
The fifth item under consideration is identified as the CONNECT OverSleeve Rugged, SKU 72423, which is
described as a plastic sleeve designed to fit around an iPort CONNECT and is intended to provide physical
protection to the iPort CONNECT and to the tablet PC placed within the iPort CONNECT. This protective
sleeve does not have charging or interconnection capabilities and is compatible with both the CONNECT
PRO and CONNECT Cases for the tablet PC, providing enhanced durability for retail and commercial
environments.
In your letter, you suggest a secondary classification for the OverSleeve Rugged under subheading
3926.90.99, HTSUS. As the CONNECT OverSleeve Rugged, would be considered an article of plastic, and
as it is not more specifically provided for elsewhere, we agree with the secondary suggested tariff
subheading.
The applicable subheading for the CONNECT PRO Case Air11 M3 BK, SKU 72324, the CONNECT PRO
Case iPadA16 BK-V3, SKU 72447, the C-PRO UTILITY CASE 11PRO M4 GN, SKU 72494, and the
CONNECT PRO Case iPad A16 BK, SKU 72340, will be 8473.30.5100, HTSUS, which provides for "Parts
and accessories (other than covers, carrying cases and the like) suitable for use solely or principally with
machines of heading 8470 to 8472: . . . Parts and accessories of the machines of heading 8471: Not
incorporating a cathode-ray tube: . . .Other." The general rate of duty will be Free.
The applicable subheading for the CONNECT OverSleeve Rugged, SKU 72423, will be 3926.90.9989,
HTSUS, which provides for “Other articles of plastics and articles of other materials of headings 3901 to
3914: Other: Other: Other.” The general rate of duty is 5.3 percent ad valorem.
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 8473.30.5100 and 3926.90.9989, 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
8473.30.5100 and 3926.90.9989, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8473.30.5100, 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, i.e.,
9903.88.03, in addition to subheading 8473.30.5100, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 3926.90.9989, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e.,
9903.88.15, in addition to subheading 3926.90.9989, 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 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, contact
National Import Specialist Karl Moosbrugger at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division