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 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 SURFACE MOUNT System iPadA16BK, SKU 70810,
which is described as an aluminum bezel that is used to encase a tablet personal computer (PC) and provide a
physical mounting capability on a wall or flat surface. The SURFACE MOUNT System iPadA16BK is
imported with a USB-C adapter cable and an iPort POE+ network adapter. In use, a tablet PC is placed
inside the SURFACE MOUNT System iPadA16BK and secured to the wall for interaction with users. The
SURFACE MOUNT System iPadA16BK is specifically designed for the tablet PC by positioning
microphone/speaker holes and charging port alignments.
The second item under consideration is identified as the SURFACE MOUNT System mini BK, SKU 70805,
which is described as an aluminum bezel that is used to encase a tablet PC and provide a physical mounting
capability on a wall or flat surface. The SURFACE MOUNT System mini BK is imported with a USB-C
adapter cable and an iPort POE+ network adapter. In use, a tablet PC is placed inside the SURFACE
MOUNT System mini BK and secured to the wall for interaction with users. The SURFACE MOUNT
System mini BK is specifically designed for the tablet PC by positioning microphone/speaker holes and
charging port alignments.
The third item under consideration is identified as the SURFACE MOUNT System iPadA16WH, SKU
70811, which is described as an aluminum bezel that is used to encase a tablet PC and provide a physical
mounting capability on a wall or flat surface. The SURFACE MOUNT System iPadA16WH is imported
with a USB-C adapter cable and an iPort POE+ network adapter. In use, a tablet PC is placed inside the
SURFACE MOUNT System iPadA16WH and secured to the wall for interaction with users. The SURFACE
MOUNT System iPadA16WH is specifically designed for the tablet PC by positioning microphone/speaker
holes and charging port alignments.
The fourth item under consideration is identified as the CONNECT MOUNT Tilt PoE+, SKU 72464, which
is described as a tilt capable mounting system used exclusively with the iPort Connect Module interface. The
CONNECT MOUNT Tilt PoE+ consists of the metal tilt mechanism, a plastic base with electrical
connections, and is imported with a CONNECT POE+ network adapter and corresponding cable assemblies.
In use, a tablet PC that is housed inside an iPort Connect Case is mounted to the CONNECT MOUNT Tilt
PoE+ for physical and electrical installation onto an existing wall for user interaction and viewing.
The fifth item under consideration is identified as the CONNECT MOUNT Pillar 1P-BK10H, SKU 72441,
which is described as a metal baseplate, a 10” post, an integrated electrical harness, and a hinged mounting
bracket. In use, the CONNECT MOUNT Pillar 1P-BK10H is placed on a desk or flat surface, a tablet PC
that is housed inside an iPort Connect Case is mounted to the hinged bracket, and the tablet PC receives an
electrical connection.
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 agree.
The applicable subheading for the SURFACE MOUNT System iPadA16BK, SKU 70810, the SURFACE
MOUNT System mini BK, SKU 70805, the SURFACE MOUNT System iPadA16WH, SKU 70811, the
CONNECT MOUNT Tilt PoE+, SKU 72464, and the CONNECT MOUNT Pillar 1P-BK10H, SKU 72441,
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.
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, HTSUS, listed above.
On March 12, 2025, Presidential proclamation 10895 imposed additional tariffs on certain
derivative aluminum products. Additional duties for derivative aluminum products of 50 percent are
reflected in Chapter 99, headings 9903.85.04 and 9903.85.07. Products provided by heading 9903.85.08 will
be subject to a duty of 50 percent upon the value of the aluminum content. At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, i.e. 9903.85.08, in addition to
subheading 8473.30.5100, HTSUS. Derivative aluminum articles processed in another country from
aluminum articles that were smelted and cast in the United States, provided for in heading 9903.85.09, are
not subject to the additional ad valorem duties.
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. For products covered by heading
9903.85.08, this additional duty applies to the non-aluminum content of the merchandise. 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, 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.
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