CLA-2-90:OT:RR:NC:N1:105
9903.88.01; 9903.88.02
Farhad Arvin
Choovio Inc.
23191 La Cadena Drive, Suite 102
Laguna Hills, CA 92653
RE: The tariff classification of sensors from China
Dear Mr. Arvin:
In your letter dated June 25, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The first item under consideration is the Senstick SSM40, which is a LoRaWAN-based soil moisture sensor
designed to monitor volumetric water content in soil. It operates autonomously for up to 7 years in harsh
conditions, making it particularly useful in remote or unattended environments. The SSM40 generates
variable electrical signals corresponding to the Volumetric Water Content (VWC) of the soil, ranging from
0% to 100%. These signals are interpreted internally and converted into digital data, which is then
transmitted over LoRaWAN. The output is a calibrated measurement, not just a simple trigger. It delivers
real-time, quantitative readings to the user or system, which can then be viewed via dashboard or LoRaWAN
network server integration.
The sensor uses capacitive measurement technology (typical for VWC sensing) in the EC-5 soil probe, which
detects dielectric changes in the soil to determine water content. The sensing element is part of an EC-5
probe, which is recognized industry-wide for high-accuracy readings in soil environments. Additionally, the
unit includes motion detection (accelerometer) with a sensing range of ±2g to ±16g, which may help detect if
the sensor has been moved or disturbed (useful for anti-tamper or deployment verification).
The second item under consideration is the KARE+ 3-in-1 sensor, which is designed to monitor indoor
environmental conditions. It integrates three key sensing functions including smoke detection, temperature
measurement, and humidity measurement. The sensor is designed to alert occupants to smoke, track room
temperature for comfort, and monitor humidity for mold prevention. The sensor is used to maintain suitable
living conditions, to monitor room climate and detect environmental anomalies early as a supplement to
non-connected smoke detectors, and offers smart monitoring with LoRaWAN connectivity. Each sensor in
the device provides variable electrical output that represents measurements, which are processed and
transmitted via LoRaWAN 915 MHz to a gateway or compatible platform. The temperature and humidity
sensors provide precise, calibrated measurement values. The smoke detector uses a photoelectric (optical)
sensing method to generate signals indicating smoke presence. These outputs are formatted as data packets
that represent real measurements, not just binary alert signals. The device provides actual calibrated
measurements including temperature in degrees Celsius (°C) with a range of -30°C to +70°C and humidity in
percentage relative humidity (0-100% RH).
The smoke sensor, while using optical technology, also triggers an alert with details transmitted through the
network and produces a local audible alarm (85 dB at 3 meters). The smoke detector has photoelectric
detection using the Tyndall effect (scattering of light by smoke particles). The smoke alarm alerts to fire or
burning material, which enhances occupant safety. The temperature sensor allows for environmental control,
detection of HVAC malfunctions, or risk of overheating/freezing, while the humidity sensor helps prevent
mold growth, identify leaks, and maintain comfort levels.
The third item under consideration is the LHT65N-VIB, which is a LoRaWAN-enabled vibration sensor used
to detect and measure vibrations, shocks, or accelerations of an object in real time. It is typically deployed for
machine monitoring while detecting abnormal vibration patterns to predict mechanical failure, pump
monitoring by notifying maintenance teams when unexpected motion occurs, and water leak detection when
used in combination with environmental clues or sudden vibrations (e.g., pipe bursts).
The device is built for remote, professional applications where long-range data transmission and low-power
consumption is critical. The LHT65N-VIB outputs calibrated sensor readings representing vibration intensity
and status using a 3-axis accelerometer (x, y, z). It also provides environmental readings such as temperature
(°C) and humidity (%RH). Users receive these readings over LoRaWAN, which can be visualized via
dashboards or trigger cloud-based alerts/actions. The temperature sensing is designed to monitor equipment
operating environments, provide early warning for overheating or environmental stress, and supplement
vibration data for more complete diagnostics. The humidity sensor is similar and can flag issues like
condensation in sensitive machinery.
The fourth item under consideration is the RB11E, which is a multi-functional LoRaWAN sensor designed
for indoor environmental monitoring. It combines occupancy detection, temperature sensing, and light level
monitoring in a single compact device. The sensor can be used to detect human presence to automate lighting
and HVAC systems, trigger systems based on room usage to reduce power waste, and alert if motion is
detected during scheduled non-occupancy hours. The sensor can also provide lighting control where it can
adjust lighting based on ambient light readings. The RB11E generates calibrated digital measurements
transmitted via LoRaWAN. Each sensor’s data is represented as a structured variable (not raw voltage),
understandable by compatible gateways or platforms. The temperature is provided in degrees Celsius (20°C
to 55°C), light levels in Lux (range 2–1100 Lux), occupancy sensor using a Fresnel lens for a wide sensing
field (horizontal: 110°, vertical: 60°), occupancy detection via a binary motion alert (event trigger), tamper
alert via an event-based trigger, and battery level in Volts (±0.1V accuracy).
Each sensor triggers signal transmission when thresholds are crossed or periodic reports are scheduled. There
are no built-in audible or visual alarms, however, alerts can be sent to external systems which can be
configured to activate alarms, lights, or notifications.
The fifth item under consideration is the Strips Multi-sensor +Guard, an ultra-slim magnetic contact sensor
designed for monitoring windows, doors, gates, and valuable items. The sensor can provide building security
by detecting unauthorized entry by alerting when doors/windows are opened. It can also automatically
disable the HVAC systems when windows are opened, monitor environmental conditions and intrusion in
commercial and residential buildings, discreetly monitor access to drawers, cabinets, or even behind picture
frames for security in museums, offices, and homes.
The sensor’s ultra-thin (3mm) and long-range (up to 10 km) design allows for hidden indoor or outdoor
installations, making it highly flexible for both professional and consumer IoT applications. The sensor
generates LoRaWAN radio packets that encode Open/Close (binary signal from the magnetic contact sensor)
and temperature data (variable calibrated measurement in °C/°F).
In your letter, you suggest the applicable classification for the sensors to be within heading 8517,
Harmonized Tariff Schedule of the United States (HTSUS). Heading 8517, HTSUS, provides in relevant part
for: “…other apparatus for the transmission or reception of voice, images or other data, including apparatus
for communication in a wired or wireless network (such as a local or wide area network)…” The items
concerned have a primary function of measuring/ detecting/ sensing various environmental conditions. They
also have a secondary function of transmitting that information to a remote location. As per the Explanatory
Notes to heading 8517, carrier-current and other transmitters and receivers which form a single unit with
analogue or digital telemetering instruments or apparatus, or which, together with the latter, constitute a
functional unit within the meaning of Note 3 to Chapter 90 are excluded from heading 8517. Additionally,
Section XVI Note 1 (m) excludes items classifiable within chapter 90. Classification under heading 8517,
HTSUS, is precluded because the devices concerned are used primarily to execute a measurement function
and as such are excluded from heading 8517, HTSUS.
Accordingly, the applicable subheading for the Senstick SSM40 will be 9025.80.1000, HTSUS, which
provides for “Hydrometers and similar floating instruments, thermometers, pyrometers, barometers,
hygrometers and psychrometers, recording or not, and any combination of these instruments; parts and
accessories thereof: Other instruments: Electrical.” The general rate of duty will be 1.7 percent ad valorem.
The remaining sensors at issue are all composite goods in which no single element imparts the essential
character to the devices. Consequently, the sensors would be classified in accordance with General Rule of
Interpretation GRI 3(c), which indicates that the goods would be classified under the heading which occurs
last in numerical order among those which equally merit consideration.
For item 2, heading 9025, which provides for instruments for measuring temperature and humidity, is the
heading that appears last among those that equally merit consideration. The applicable subheading for the
KARE+ 3-in-1 sensor will be 9025.80.1000, HTSUS, which provides for “Hydrometers and similar floating
instruments, thermometers, pyrometers, barometers, hygrometers and psychrometers, recording or not, and
any combination of these instruments; parts and accessories thereof: Other instruments: Electrical.” The
general rate of duty will be 1.7 percent ad valorem.
For item 3, heading 9031, which provides for instruments for measuring vibration, is the heading that appears
last among those that equally merit consideration. The applicable subheading for the LHT65N-VIB will be
9031.80.8085, HTSUS, which provides for “Measuring or checking instruments, appliances and machines,
not specified or included elsewhere in this chapter; profile projectors; parts and accessories thereof: Other
instruments, appliances and machines: Other: Other.” The general rate of duty will be free.
For item 4, heading 9027, which provides for instruments and apparatus for physical and chemical analysis
and measuring or checking quantities of heat, sound or light, is the heading that appears last among those that
equally merit consideration. The applicable subheading for the RB11E will be 9027.50.4050, HTSUS, which
provides for “Instruments and apparatus for physical or chemical analysis (for example, polarimeters,
refractometers, spectrometers, gas or smoke analysis apparatus); instruments and apparatus for measuring or
checking viscosity, porosity, expansion, surface tension or the like; instruments and apparatus for measuring
or checking quantities of heat, sound or light (including exposure meters); microtomes; parts and accessories
thereof: Other instruments and apparatus using optical radiations (ultraviolet, visible, infrared): Other:
Electrical: Photometers.” The general rate of duty will be free.
For item 5, heading 9025, which provides for instruments for measuring temperature, is the heading that
appears last among those that equally merit consideration. The applicable subheading for the Strips
Multi-sensor +Guard sensor will be 9025.19.8085, HTSUS, which provides for “Hydrometers and similar
floating instruments, thermometers, pyrometers, barometers, hygrometers and psychrometers, recording or
not, and any combination of these instruments; parts and accessories thereof: Thermometers and pyrometers,
not combined with other instruments: Other: Other: Other: 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 subheadings 9025.19.8085, 9025.80.1000, 9027.50.4050, and 9031.80.8085 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 subheadings
9025.19.8085, 9025.80.1000, 9027.50.4050, and 9031.80.8085, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 9027.50.4050 and 9031.80.8085, 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 9903.88.01 in addition to subheadings 9027.50.4050 and 9031.80.8085, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 9025.19.8085 and 9025.80.1000, 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 9903.88.02 in addition to subheadings 9025.19.8085 and 9025.80.1000, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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 Jason Christie at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division