CLA-2-85: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 BaseStation BK, SKU 72352, which
is described as a metal base with a plastic housing incorporating a specialized electrical connector that is
intended to couple with a separate device noted as the iPort Connect Module. The CONNECT PRO
BaseStation BK has an input power socket and comes with the corded switching power adapter. In use, the
CONNECT PRO BaseStation BK is placed onto a surface where users can magnetically attach their personal
tablet personal computer (PC), equipped with the iPort Connect Module, to receive power. Based on the
information provided, the power adapter converts source AC electricity to 24 VDC 1.7 A output to the
CONNECT PRO BaseStation.
The second item under consideration is identified as the CONNECT PRO WallStation BK, SKU 72350,
which is described as a wall-mountable plastic housing incorporating a specialized electrical connector that is
intended to couple with the iPort Connect Module. The CONNECT PRO WallStation BK has an input
power socket and comes with a corded switching power adapter. In use, the CONNECT PRO WallStation
BK is mounted to a wall where users can magnetically attach their personal tablet personal computer (PC),
equipped with the iPort Connect Module, to receive power. Based on the information provided, the power
adapter converts source AC electricity to 24 VDC 1.7 A output to the CONNECT PRO WallStation BK.
Included with the CONNECT PRO WallStation BK are various connectors and adapter cords that facilitate
connection options.
The third item under consideration is identified as the CONNECT PRO WallStation WH, SKU 72351, which
is described as a wall-mountable plastic housing incorporating a specialized electrical connector that is
intended to couple with the iPort Connect Module. The CONNECT PRO WallStation WH has an input
power socket and comes with a corded switching power adapter. In use, the CONNECT PRO WallStation
WH is mounted to a wall where users can magnetically attach their personal tablet personal computer (PC),
equipped with the iPort Connect Module, to receive power. Based on the information provided, the power
adapter converts source AC electricity to 24 VDC 1.7 A output to the CONNECT PRO WallStation WH.
Included with the CONNECT PRO WallStation WH are various connectors and adapter cords that facilitate
connection options.
The fourth item under consideration is identified as the CONNECT PRO BaseStation WH, SKU 72353,
which is described as a metal base with a plastic housing incorporating a specialized electrical connector that
is intended to couple with a separate device noted as the iPort Connect Module. The CONNECT PRO
BaseStation WH has an input power jack and comes with the corded switching power adapter. In use, the
CONNECT PRO BaseStation WH is placed onto a surface where users can magnetically attach their personal
tablet personal computer (PC), equipped with the iPort Connect Module, to receive power. Based on the
information provided, the power adapter converts source AC electricity to 24 VDC 1.7 A output to the
CONNECT PRO BaseStation.
The fifth item under consideration is identified as the CONNECT MultiDock 8 IPAD, SKU 72308, which is
described as a plastic charging dock designed to accommodate six individual tablets for the purpose of
charging the individual devices. The CONNECT MultiDock 8 IPAD has one charge indicator for each tablet
slot and is imported with a corded power adapter that converts source AC electricity to 19 VDC that is
distributed to each tablet slot for the purpose of charging the tablets.
In your letter, you suggest the subject merchandise is properly classifiable under subheading 8473.30.5100,
Harmonized Tariff Schedule of the United States (HTSUS). We disagree. While the devices under
consideration herein may be used with machines of heading 8471, namely tablet PCs, the function of
electrical static conversion is specifically provided for under heading 8504, HTSUS.
The applicable subheading for the CONNECT PRO BaseStation BK, SKU 72352, the CONNECT PRO
WallStation BK, SKU 72350, the CONNECT PRO WallStation WH, SKU 72351, the CONNECT PRO
BaseStation WH, SKU 72353, and the CONNECT MultiDock 8 IPAD, SKU 72308, will be 8504.40.9550,
HTSUS, which provides for “Electrical transformers and static converters…: Other: Rectifiers and rectifying
apparatus: 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 8504.40.9550, 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
8504.40.9550, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8504.40.9550, 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 8504.40.9550, 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/.
Importations of this product may be subject to the provisions of Section 133 of the Customs Regulations if
they copy or simulate a registered trademark, trade name or copyright recorded with U.S. Customs and
Border Protection. If you are an authorized importer of the product we recommend notifying your local
Customs office prior to importation.
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